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HomeMy WebLinkAbout18 2023 WIldfire Mitigation AGENDA ITEM #18 Public Utility District m MEETING DATE: June 7, 2023 TO: Board of Directors FROM: Steven Poncelet, Public Information Officer SUBJECT: Consideration of Approval of the TDPUD 2023 Wildfire Mitigation Plan and Independent Evaluation APPROVED BY: Brian C. Wright, General Manager RECOMMENDATION: Approve the TDPUD 2023 Wildfire Mitigation Plan and Independent Evaluation reports in substantially the same form and direct staff to file with the Wildfire Advisory Safety Board before July 1, 2023. BACKGROUND: Devastating wildfires throughout the state of California have prompted electric utilities to identify areas within their jurisdiction that are susceptible to power-line ignited wildfires and to take steps to prevent their occurrence. In 2012, the California Public Utilities Commission (CPUC) ordered the development of a statewide map (Fire-Threat Map) designed to identify areas where there is an increased risk for utility associated wildfires. Publicly Owned Utilities (POUs), including the District, participated in development of the Fire-Threat Map and performed the assessment of the geographical areas under our responsibility. In September 2018, former Governor Jerry Brown signed state Senate Bill (SB) 901 . A section of the bill, amending Public Utilities Code Section 8387, directed California's electric utilities to develop wildfire mitigation plans related to power lines and equipment. POUs, such as the District, are required to annually prepare a Wildfire Mitigation Plan (WMP); receive an initial third party auditor independent review to assess compliance and ensure it complies with all applicable rules, regulations, and standards; and present it to their governing body annually at a noticed public meeting for comment and approval. Staff presented two workshops to the Board in March and June, 2019, followed by Board adoption of the District's initial 2019 WMP in July of the same year. In October 2019, the Board awarded a contract for third party auditor services to review and comment on the WMP and their findings were presented to the Board during a public meeting for consideration in December of 2019. The third party auditor confirmed the District's plan complies with the intent of SB 901 and their recommendations were Page 1 of 4 Page 56 of 315 considered in the updated 2020 WMP which was approved by the Board in May of 2020 and sent to the California Wildfire Safety Advisory Board (WSAB) by July 1, 2020. In July of 2020, the WSAB began reviewing WMPs for POUs and Investor Owned Utilities (IOUs). This review process has continued to evolve, requiring utilities to respond to a series of additional information requests and formatting changes by the WSAB. Key changes include adding a context setting table at the beginning of the WMP and expanding the introduction to summarize key changes to the WMP. These additions were included in the District's 2021 and 2022 annual WMP updates which were approved by the District's Board. Annually, the WASB releases a Guidance Advisory Opinion for the Wildfire Mitigation Plans of the Electric POUs and Rural Electric Cooperatives. The most recent WASB document was in response to the POU's 2022 WMP's submitted before July 1, 2022 and contained a series of general guidance for all POU WMP's and then specific feedback for each electric utility. The specific feedback for the District's 2022 WMP was very favorable and the District was highlighted by the WASB. However, the general guidance for all POU's had some problematic recommendations that District staff, through the California Municipal Utilities Association (CMUA) and Northern California Power Agency (NCPA) are working closely with WASB Board and staff to address. All WMP's are required by statute to have a comprehensive update every three years. This comprehensive update was planned for the District's 2023 WMP, where WASB's guidance will also be addressed. In addition, future versions of the WMP are expected to evolve as the WSAB attempts to standardize the required data, supporting documentation, metrics, lessons learned and formatting of the WMPs across all utilities. ANALYSIS AND BODY: The Truckee Donner Public Utility District 2023 Wildfire Mitigation Plan (2023 WMP) is the comprehensive update and is included as Attachment 1. As in previous years, this WMP outlines the processes and activities undertaken by the District to mitigate the threat of wildfires associated with overhead electric lines and associated equipment owned and operated by the District. Developing the WMP is part of larger District wildfire prevention efforts which include the identification of emerging technologies, engineering control methods, improved materials, and increased vegetation management activities. It also identifies deficiencies of the plan and efforts to resolve them. To help with the comprehensive update, the District's Board, through the annual procurement process, awarded a contract to Dudek. Dudek is one of the few consultants qualified in California to perform this type of work, and has a contract with NCPA's Shared Service Procurement Agreement (SSPA) to serve NCPA's member utilities. The process of the comprehensive update also included significant work by the CMUA's Wildfire Preparedness, Response, and Recovery Working Group, which created six sub-working groups to address key elements of WMP's including: Metrics, Vegetation Management, Asset Management, Grid Design and System Hardening, Risk Modeling, and Climate change. District staff participated in each of these sub-working groups and Page 2 of 4 Page 57 of 315 the valuable information shared informed the WMP's comprehensive update. The 2023 WMP has been updated to reflect current practices and procedures and provides updates on the District's mitigation programs, progress, and metrics. It should be noted that the District, since the last WMP, has implemented the new Outage Management System (OMS) which offers significant improvements in outage reporting, response, and communications. The new OMS was included in the updated WMP. Historically, the District has tracked and reported annually two metrics since the induction of the WMP: Primary Wire Down and Fires caused by District Electric Equipment. For the 2023 WMP, the District added a third metric, Outage Causes, which can now be tracked through the District's new OMS. In addition, for all three metrics, the District for the 2023 WMP is only reporting these metrics during wildfire season (typically June 1 through October 31) given that most of the District's outages occur during winter storms and atmospheric rivers when wildfire danger is not a concern. Reporting winter outage statistics outside of wildfire season makes the metrics less effective. During 2022, the District recorded the following metrics during the wildfire season: • Primary Wire Down; Zero (0) events; • Fire caused by District Electric Equipment; Zero (0) events; and • Outages Causes: 309 The outage causes range from equipment failures to animal contacts to human-caused outages. It should be noted that the District's wildfire mitigation practice of placing reclosers on 'one shot' does increase the length of intermittent contact wildfire season outages. Full details can be found in the 2023 WMP. The District chose for the 2023 WMP comprehensive update to contract for independent evaluation services, which was last done in 2020 with the original plan. The District's Board, through the annual procurement process, awarded a contract to Guidehouse (formerly Navigent who did the District's initial independent evaluation). Guidehouse is one of the few consultants qualified in California to perform this type of work, and has a contract with NCPA's Shared Service Procurement Agreement (SSPA) to serve NCPA's member utilities. Guidehouse's Independent Evaluation of Truckee Donner Public Utility District's 2023 Wildfire Mitigation Plan is Attachment 2. The report concludes that: • TDPUD's WMP aligns appropriately with PUC Section 8387 and includes all required elements; and • TDPUD's WMP is comprehensive as described through this Report in accordance with PUC Section 8387. GOALS AND OBJECTIVES: Page 3 of 4 Page 58 of 315 District Code 1 .05.020 Objectives: 1. Responsibly serve the public. 4. Provide reliable and high quality electric supply and distribution system to meet current and future needs. 5. Manage the District in an environmentally sound manner. 6. Manage the District in an effective, efficient and fiscally responsible manner. District Code 1 .05.030 Goals: 1. Manage for Financial Stability and Resiliency 2. Environmental Stewardship: Create a sustainable resilient environment for all our communities. FISCAL IMPACT: The costs of complying with Senate Bill 901 and implementing the District's Wildfire Mitigation Plans have been significant and were considered in past District budgets and will be considered in future District budgets. However, there is no direct Fiscal Impact associated with the approval of the TDPUD 2023 Wildfire Mitigation Plan and Independent Evaluation and submission to the Wildfire Advisory Safety Board. ATTACHMENTS: 1. TDPUD 3 Yr Revision Final with TDPUD May updates - ATTACHMENT 1 2. TDPUD Wildfire Management Plan Independent Evaluation 2023 - ATTACHMENT 2 Page 4 of 4 Page 59 of 315 ATTACHMENT 1 TRUCKEE DONNE T , t �MPublic Utility Distric WILDFIRE MITIGATION PLAN VERSION 4.0 (FOURTH ANNUAL AND FIRST COMPREHENSIVE UPDATE) May 22, 2023 Page 60 of 315 TABLE OF CONTENTS Acronyms and Abbreviations.................................................................................................iv I. Utility Overview and Context ....................................................................................... 1 A. Utility Description and Context Setting Table................................................................................l B. Statutory Cross Reference Table.....................................................................................................6 C. Process for Utility Adoption and Submittal of Annual WMP and Opportunities for Public Comment ........................................................................................................................................12 D. Description of Where WMP Information Can Be Found on Utility Website .........................12 E. Purpose of the WMP.......................................................................................................................12 F. Organization of the WMP ..............................................................................................................13 II. Objectives of the WMP................................................................................................ 13 A. Minimizing Sources of Ignition .......................................................................................................13 B. Resiliency of the Electric Grid........................................................................................................ 13 C. Minimizing Unnecessary or Ineffective Actions...........................................................................13 III. Roles and Responsibilities........................................................................................... 14 A. TDPUD Roles and Responsibilities.................................................................................................. 14 B. Coordination with Water Utilities/Department............................................................................15 C. Coordination with Communication Infrastructure Providers..................................................... 16 D. Standardized Emergency Management System .......................................................................16 IV. Wildfire Risks and Drivers ............................................................................................ 18 A. Particular Risks and Drivers Associated with Design, Construction, Operation, and Maintenance ..................................................................................................................................18 B. Particular Risks and Risk Drivers Associated with Topographical and Climatological Risk Factors..............................................................................................................................................19 Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 Page 61 of 315 ClimateChange................................................................................................................................19 C. Enterprise-Wide Safety Risks...........................................................................................................19 D. Changes to the CPUC Fire Threat Map .......................................................................................20 V. Wildfire Preventative Strategies.................................................................................. 20 A. High Fire Threat Map for TDPUD ....................................................................................................20 BWeather Monitoring .......................................................................................................................21 C. Design and Construction Standards ............................................................................................22 PoleReplacement Program ............................................................................................................22 Non-expulsion Current Limiting Fuses..............................................................................................22 FR3Insulating Fluid.............................................................................................................................23 Covered Primary Jumper Wire.........................................................................................................23 Proposed Service Requirements......................................................................................................23 Tree Attachments (Legacy Attachments) .....................................................................................24 Advanced Metering Infrastructure..................................................................................................24 Outage Management System.........................................................................................................25 Supervisory Control and Data Acquisition......................................................................................25 D. Vegetation Management.............................................................................................................26 E. Inspections.......................................................................................................................................27 F. Workforce Training..........................................................................................................................27 G. Recloser Policy................................................................................................................................27 H. De-energization ..............................................................................................................................28 Impactsto Public Safety...................................................................................................................29 Customer Notification Protocols......................................................................................................29 VI. Community Outreach and Public Awareness.......................................................... 30 VII. Restoration of Service................................................................................................. 31 Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 April 28, 2023 II Page 62 of 315 Vill. Evaluating the Plan ..................................................................................................... 32 A. Metrics and Assumptions for Measuring Plan Performance......................................................32 B. Impacts of Metrics on the Plan .....................................................................................................33 C. Monitoring and Auditing the Plan ................................................................................................33 D. Identifying and Correcting Deficiencies in the Plan ..................................................................34 E. Monitoring the Effectiveness of Inspections................................................................................34 F. Independent Auditor.....................................................................................................................34 IX. WMP Adoption Process............................................................................................... 35 X. References................................................................................................................... 36 FIGURE Figure 1 TDPUD Electric Service Territory Map ....................................................................................... 1 1 APPENDICES A CPUC High Fire Threat District Map for the Truckee Donner Public Utility B Prevailing Wind Map C Pole Replacement Ranking Tool D Vegetation Management Program Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 April 28, 2023 III Page 63 of 315 ACRONYMS AND ABBREVIATIONS �rAcronym/Abbreviation Definition AGM Assistant General Manager AMI advanced metering infrastructure CAL FIRE California Department of Forestry and Fire Protection CPUC California Public Utilities Commission ELF Energy Limiting Fuse GIS geographic information system GO General Order HFTD High Fire Threat District kV kilovolt NCJPA Northern California Joint Pole Association NISC National Information Solutions Cooperative OMS Outage Management System PIO Public Information Officer PSOM Public Safety Outage Management PSPS Public Safety Power Shutdown RFW Red Flag Warning SCADA Supervisory Control and Data Acquisition SEMS Standardized Emergency Management System TDPUD Truckee Donner Public Utility District VMP Vegetation Management Plan WMP (or Plan) Wildfire Mitigation Plan Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 IV Page 64 of 315 TILITY OVERVIEW AND CONTEXT A. UTILITY DESCRIPTION AND CONTEXT SETTING TABLE The Truckee Donner Public Utility District (TDPUD) is a special district of the State of California engaged in the distribution, sale, and delivery of electric power and water. TDPUD provides retail electric service to about 14,648 customers as of December 31, 2022 and the region has a large transient population driven by second home owners and destination tourism which can increase population by two to three plus times. TDPUD is a transmission-dependent utility connected to NV Energy's transmission system and is located high on the eastern slope of the Sierra Nevada. TDPUD is not directly interconnected with the California transmission system nor to any California utility in a meaningful way. TDPUD's electric service territory comprises approximately 44 square miles in eastern Nevada County and approximately 1.5 square miles in adjacent Placer County. The electric system includes approximately 225 miles total with 135 miles of 12.47 kilovolt (kV) and 14.4 kV overhead distribution lines, and about 0.5 miles of 60 kV overhead transmission lines. In total, TDPUD has 5,490 poles in its service territory (Figure 1). Utility Name 19 Truckee Donner PublicD' Service Territory Size 45.5 square miles Owned Assets X❑ Transmission X❑ Distribution ❑ Generation Number of Customers Served 14,648 customer accounts Population Within Service Territory 17,131 people Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 1 Page 65 of 315 tility Name Truckee Donner PublicD' Number of Accounts Share of Total Load(MWh) 88.65% Residential 59.96% Residential Customer Class Makeup 2.07% Government 16.64% Government 0%Agricultural 0%Agricultural 9.23% Small/Medium Business 20.11% Small/Medium Business .05% Commercial/Industrial 3.29% Commercial/Industrial .039%Agriculture 2.641% Barren/Other Service Territory 54.95%Conifer Forest 0%Conifer Woodland 0% Desert .75% Hardwood Forest Location/Topography' 0% Hardwood Woodland2.99% Herbaceous Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 2 Page 66 of 315 tility Name Truckee Donner PublicD' 26.92%Shrub 7.66% Urban 4.11%Water Service Territory Wildland 29.56%Wildland Urban Interface Urban Interface'(based on total area) 19.90%Wildland Urban Intermix ❑X Includes maps (Appendix A) Percent of Service Territory in CPUC High Fire Tier 2: 55.07% Threat Districts(based on totalarea) Tier 3: 27.15% X❑ Includes maps (Appendix B) Prevailing Wind Directions Prevailing winds were taken from both the Global Winds Atlas and Wind Rose and Speeds by Season data from archived records and assembled by Iowa State University. Gradient winds are generally out of the south/southwest shifting to west/southwest in the spring and summer months.The average wind speed is 4.4 mph with frequent gust in excess of 20 mph throughout the year.TDPUD's extreme 1 Based on the Wildland Urban Interface Maps available from the U.S. Geological Survey website titled "Wildland-urban interface maps for the conterminous U.S. based on 125 million building locations" (Carlson et al. 2022). Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 3 Page 67 of 315 tility Name Truckee Donner Public � ' =A weather and wind events occur in winter months when wildfire threat is typically low.These events are caused by atmospheric rivers and can bring winds in excess of 100 mph.These atmospheric river events and heavy snow falls are the reason TDPUD builds to a heavy loading standard and is able to withstand extreme weather events. Source: https:Hglobalwindatlas.info; https:Hmesonet.agron.iastate.edu/sites/windrose.phtmI?network=CA—ASOS &station=TRK Overhead Dist.: 134.7 miles Overhead Trans.: 0.3 miles Underground Dist.: 97.6 miles Underground Trans.: 0 miles Miles of Owned Lines Underground Explanatory Note 1-Methodology for Measuring "Miles": [e.g., circuit miles, and/or Overhead line miles.] Data from GIS system Explanatory Note 2—Description of Unique Ownership Circumstances: N/A Explanatory Note 3—Additional Relevant Context: [e.g., percentage of lines located outside service territory] N/A Overhead Distribution Lines as%of Total Distribution System (Inside and Outside Service Territory) Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 4 Page 68 of 315 Utility Name Truckee Donner PublicD' Percent of Owned Lines in CPUC High Fire Threat Tier 2: 23.02% Districts Tier 3:40.59% Overhead Transmission Lines as%of Total Transmission System (Inside and Outside Service Territory) Tier 2: < 1% Tier 3: 0% Explanatory Note 4—Additional Relevant Context: [e.g., explain any difference from data reported in WMP due to different numerator used for this form] Customers have ever lost ❑ Yes X❑ No service due to an IOU PSPS event? Customers have ever been ❑ Yes X❑ No notified of a potential loss of service to due to a forecasted IOU PSPS event? Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 5 Page 69 of 315 Utility Name Truckee Donner PublicD' Has developed protocols ❑ Yes ® No to pre-emptively shut offelectricity in response toelevated wildfire risks? ❑ Yes © No If yes,then provide the following data for calendar year 2022: Has previously preemptively shut off electricity in response to Number of shut-off events: N/A elevated wildfire risk? Customer Accounts that lost service for>10 minutes: N/A For prior response, average duration before service restored: N/A Notes:TDPUD=Truckee Donner Public Utility District;CPUC=California Public Utilities Commission;GIS=geographic information system; N/A=not applicable;IOU=Investor-Owned Utilities;PSPS=Public Safety Power Shutdown. B. STATUTORY CROSS REFERENCE TABLE rRequirement Stat LL WMP PUC Section 8387(b)(2)(A):An accounting of the Persons Section: 3 responsibilities of persons responsible for executing Responsible Pages: 11-12 the plan. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 6 Page 70 of 315 Requirement • ML; WMP U 90L di Objectives of the PUC Section 8387(b)(2)(B):The objectives of the Section: 2 Plan wildfire mitigation plan. Page: 8 PUC Section 8387(b)(2)(C):A description of the preventive strategies and programs to be adopted by the local publicly owned electric utility or Preventive Section: 2 electrical cooperative to minimize the risk of its Strategies Pages: 9-10 electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks. PUC Section 8387(b)(2)(D):A description of the metrics the local publicly owned electric utility or Evaluation Section: 8 electrical cooperative plans to use to evaluate the Metrics Page: 30 wildfire mitigation plan's performance and the assumptions that underlie the use of those metrics. PUC Section 8387(b)(2)(E):A discussion of how the Impact of Metrics application of previously identified metrics to Section: 8 previous wildfire mitigation plan performances has Page: 30 informed the wildfire mitigation plan. PUC Section 8387(b)(2)(F): Protocols for disabling reclosers and de-energizing portions of the electrical distribution system that consider the associated De-energization impacts on public safety and protocols related to Section: 5 Protocols mitigating the public safety impacts of those Page: 24 protocols, including impacts on critical first responders and on health and communication infrastructure. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 7 Page 71 of 315 "equirement WMP PUC Section 8387(b)(2)(G):Appropriate and feasible Customer procedures for notifying a customer who may be Notification impacted by the de-energizing of electrical lines. The Section: 5 Procedures procedures shall consider the need to notify, as a Page: 23 priority, critical first responders, health care facilities, and operators of telecommunications infrastructure. Vegetation PUC Section 8387(b)(2)(H): Plans for vegetation Section: 5 Management management. Pages: 19-21 PUC Section 8387(b)(2)(1): Plans for inspections of Section: 5 Inspections the local publicly owned electric utility's or electrical Page: 21 cooperative's electrical infrastructure. PUC Section 8387(b)(2)(J):A list that identifies, describes,and prioritizes all wildfire risks, and drivers for those risks,throughout the local publicly s owned electric utility' or electrical cooperative's service territory. The list shall include, but not be limited to, both of the following: Prioritization of (i) Risks and risk drivers associated with design, Section:4 Wildfire Risks construction, operation, and maintenance of the local Pages: 17-18 publicly owned electric utility's or electrical cooperative's equipment and facilities. (ii) Particular risks and risk drivers associated with topographical and climatological risk factors throughout the different parts of the local publicly owned electric utility's or electrical cooperative's service territory. CPUC Fire Threat PUC Section 8387(b)(2)(K): Identification of any Section:4 Map Adjustments geographic area in the local publicly owned electric page: 18 utility's or electrical cooperative's service territory Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 8 Page 72 of 315 • • k I • . • � - that is a higher wildfire threat than is identified in a commission fire threat map, and identification of where the commission should expand a high fire threat for TDPUD based on new information or changes to the environment. PUC Section 8387(b)(2)(L):A methodology for Enterprise-wide Section: 4 identifying and presenting enterprise-wide safety risk Risks Page: 17 and wildfire-related risk. PUC Section 8387(b)(2)(M):A statement of how the Restoration of Section: 7 local publicly owned electric utility or electrical Service Pages: 28-29 cooperative will restore service after a wildfire. PUC Section 8387(b)(2)(N): A description of the processes and procedures the local publicly owned electric utility or electrical cooperative shall use to do all of the following: (i) Monitor and audit the implementation of the wildfire mitigation plan. Monitor and (ii) Identify any deficiencies in the wildfire mitigation Section: 8 Audit plan or its implementation, and correct those Page: 31 deficiencies. (iii) Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors,that are carried out under the plan, other applicable statutes, or commission rules. PUC Section 8387(c):The local publicly owned Qualified electric utilityor electrical cooperative shall contract p Section: 9 Independent with a qualified independent evaluator with Pa e: 32 Evaluator g experience in assessing the safe operation of electrical infrastructure to review and assess the Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 9 Page 73 of 315 �Requi.rement Statutory Language Location in TIDPLID's WIVIP comprehensiveness of its wildfire mitigation plan.The independent evaluator shall issue a report that shall be made available on the Internet website of the local publicly owned electric utility or electrical cooperative and shall present the report at a public meeting of the local publicly owned electric utility's or electrical cooperative's governing board. Notes:TDPUD=Truckee Donner Public Utility District;WMP=Wildfire Mitigation Plan;PUC=Public Utilities Code. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 10 Page 74 of 315 Figure lTOPUO Electric Service Territory Mop Truckee Donner Public UhRy District pGURE, Truckee Donner Public Utility normm,TenmnMap DUDEK Truckee Donner Public Utility District Wildfire Mitigation Plan Version4.O May 22' 2023 Page 75of315 C. PROCESS FOR UTILITY ADOPTION AND SUBMITTAL OF ANNUAL WMP AND OPPORTUNITIES FOR PUBLIC COMMENT The TDPUD Wildfire Mitigation Plan (WMP or Plan) is adopted by the TDPUD Board (the Board) during a public meeting. TDPUD staff present the final version of the annual WMP to the Board for review. Included with the Plan is an agenda packet with a summary of the background and the contents of the current WMP. The agenda packet also includes a description of major changes from the previous year's WMP. During the Board meeting, the adoption of the current WMP is presented as an action item. TDPUD staff present an overview of the WMP, accomplishments, and changes to the Board members and the general public. After the conclusion of the presentation, Board members allow a period for public comment. After the public comment period has ended, Board members decide whether to adopt the WMP as presented by TDPUD staff. Board meeting documents, including meeting minutes, agendas, and presentations, as well as the meeting minutes and the agenda for the adoption of the 2022 WMP, are available online at the TDPUD website: https://web.tdpud.org/WebLink/Browse.aspx?id=289229&dbid=0&repo=TDPUD. D. DESCRIPTION OF WHERE WMP INFORMATION CAN BE FOUND ON UTILITY WEBSITE The current version of TDPUD's WMP is published on the utility website on the page dedicated to wildfire mitigation, safety, and emergency preparedness. The webpage contains information about TDPUD's wildfire prevention mitigation efforts, links to sign up for emergency notification by the utility, and links to the WMP and the independent evaluator's report from 2019. This page is easily accessible from the menu on TDPUD's home page and can be found by using the search tool found on every page on the utility's website. The link to the website is: httr)s://www.tdr)ud.org/departments/wildfire-emergency-preparedness. E. PURPOSE OF THE WMP This WMP describes the range of activities and strategies TDPUD is taking to mitigate the threat of overhead power line- and equipment-ignited wildfires, including its various programs, policies, and procedures. It addresses the unique features of TDPUD's service area such as topography, weather, infrastructure, grid configuration, and potential wildfire risks. This Plan is subject to direct approval by TDPUD's Board of Directors and is implemented by the General Manager. This Plan meets or exceeds the requirements of Public Utilities Code Section 8387 for publicly owned electric utilities to prepare a WMP by January 1, 2020, and to evaluate and update annually thereafter. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 12 Page 76 of 315 F. ORGANIZATION OF THE WMP This WMP includes the following elements: • Utility overview and context • Objectives of the Plan • Roles and responsibilities for executing the Plan • Identification of key wildfire risks and risk drivers • Description of wildfire prevention strategies • Metrics for measuring performance of the Plan and identifying areas for improvement • Annual and historical results for metrics • Description of community outreach and education, covering communication about wildfire prevention, utility mitigation efforts and strategies, and potential de-energization and re-energization practices • List of references cited • Appendices 11. OBJECTIVES OF AL A. MINIMIZING SOURCES OF IGNITION The main objective of this Plan is to implement an actionable plan that will create increased reliability and safety while minimizing the probability that TDPUD's distribution system or equipment may be an original or contributing factor in the ignition of a wildfire. TDPUD has evaluated the prudent and cost-effective improvements to its physical assets, operations, and training that can help to meet this objective. Further, TDPUD is updating operational practices to reflect its commitment to prudent system management and will continue to explore new opportunities for improving the efficacy of the Plan. This Plan embraces safety, prevention, mitigation, and recovery programs that are consistent with California State Law. B. RESILIENCY OF THE ELECTRIC GRID The secondary objective of this Plan is to ensure and improve, where practicable, system resiliency. System resiliency is defined by the National Infrastructure Advisory Council as the ability to reduce the magnitude and/or duration of disruptive events. As part of the development of this Plan, TDPUD assesses new industry practices and technologies that will reduce the likelihood of a disruption in service and improve the timeline for restoration of service. C. MINIMIZING UNNECESSARY OR INEFFECTIVE ACTIONS The final objective of this Plan is to measure the effectiveness of specific mitigation strategies as they apply to TDPUD. Where a particular action, program component, or protocol is determined to be unnecessary or ineffective, TDPUD will assess whether modification or replacement is Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 13 Page 77 of 315 suitable. This approach will also help determine if more cost-effective measures would produce the same or better results.This is particularly true for the implementation of new technologies and practices where an evaluation from prototype to pilot installation to full implementation is often prudent to maximize performance and minimize unintended consequences. III. ROLES AND RESPONSIBILITIES - A. TDPUD ROLES AND RESPONSIBILITIES Customers TDPUD Board o Directors I} General Manager Electric Utility PIO/Strategic Director/AGM Affairs • Electric Electric Engineering Operations Manager Manager TDPUD utilizes a Public-Owned Utility Board/General Manager reporting hierarchy. Board members are elected at large by TDPUD customers to staggered 4-year terms, representing constituents across TDPUD's service territory. The Board President and Vice President positions are nominated and appointed by the Board annually. The Board is responsible for adoption and oversight of all policies and delegates the operational implementation of policies to the General Manager. The General Manager has full operational authority of TDPUD and operates as the Chief Executive, reporting directly to the Board. The General Manager provides direction and management to all TDPUD staff while implementing Board-adopted policy. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 14 Page 78 of 315 The Public Information Officer (PIO)/Strategic Affairs Director serves as TDPUD's public liaison to customers and outside agencies, responds to requests for information, and proactively promulgates public awareness outreach or emergency information. The Electric Utility Director/Assistant General Manager (AGM) has overall functional management of the electric utility and provides day-to-day oversight of the electric utility. The Electric Utility Director utilizes the Electric Operations Manager and Electric Engineering Manager for division oversight. The AGM also assumes the operational authority of General Manager in the absence of the General Manager. The Electric Operations Manager oversees the daily electric utility operations, including construction, maintenance, energy control, fleet, facilities, vegetation management, and other ancillary daily duties. The Electric Operations Manager maintains functional management of assigned divisions within the electric utility and reports to the Electric Utility Director/AGM. The Electric Engineering Manager oversees the design/engineering tasks associated with distribution system modification and development/maintenance of material specifications. The Electric Engineering Manager maintains functional management over the electric engineering related tasks within the electric utility and reports directly to the Electric Utility Director/AGM. TDPUD staff have the following responsibilities regarding fire prevention, response,and investigation: • Conduct work in a manner that will minimize potential fire dangers • Take all reasonable and practicable actions to prevent and suppress fires resulting from TDPUD electric facilities • Coordinate with federal, state, and local fire management personnel to ensure that appropriate preventative measures are in place • Immediately report fires pursuant to specified procedures • Take corrective action when observing or having been notified that fire protection measures have not been properly installed or maintained • Ensure compliance with relevant federal, state, and industry standard requirements • Ensure that wildfire data are appropriately collected • Practice adaptive management by reviewing past performance and data to inform and improve future plans • Maintain adequate training programs for all relevant employees B. COORDINATION WITH WATER UTILITIES/DEPARTMENT TDPUD owns and operates a water utility within its service territory, providing retail service to approximately 13,500 customers. The Electric Utility Director's office is literally adjacent to the Water Utility Director's office. When electric operations could or are known to impact the water utility, TDPUD electric and water staff will coordinate to mitigate or, where practicable, eliminate impact to electric and/or water service continuity. TDPUD electric staff collaborates proactively to notify TDPUD water staff of planned outages and communicate as quickly as Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 15 Page 79 of 315 practicable during emergency power outages that impact one or both enterprises. This emergency notification will be extended to the Truckee Fire Protection District and other agencies as needed. C. COORDINATION WITH COMMUNICATION INFRASTRUCTURE PROVIDERS TDPUD has been a member of the Northern California Joint Pole Association (NCJPA) since 2014. Members of NCJPA participate voluntarily to share expenses for the installation and maintenance of new and existing utility pole structures, as well as relinquishment or removal of those structures based on interest. TDPUD typically acts as the coordinating agency within its service territory because the majority of the structures were installed as solely owned TDPUD poles prior to joining NCJPA. The exception would be existing, solely owned communication poles within the service territory that TDPUD does not currently attach to. AT&T is the only other NCJPA member within TDPUD's service territory and is responsible for the reserved communication space on utility poles. AT&T manages the attachment of other communication providers within the communication space on joint poles. TDPUD has created a list of local agencies and key partners which does include key operational and management contacts from the communication providers, Truckee Fire Protection District, and the Town of Truckee. TDPUD also has regular communication protocols through our customer account notification, outage management system, and our website. D. STANDARDIZED EMERGENCY MANAGEMENT SYSTEM TDPUD has planning, communication, and coordination obligations pursuant to the California Governor's Office of Emergency Services' Standardized Emergency Management System (SEMS) Regulations,2 adopted in accordance with Government Code Section 8607.The SEMS Regulations specify roles, responsibilities, and structures of communications at five different levels: field response, local government, operational area, regional, and state.3 Pursuant to this structure, Z 19 California Code of Regulations Section 2407. 3 Cal.Gov.Code Section 2403(b): (1) "Field response level" commands emergency response personnel and resources to carry out tactical decisions and activities in direct response to an incident or threat. (2) "Local government level" manages and coordinates the overall emergency response and recovery activities within their jurisdiction. (3) "Operational area level" manages and/or coordinates information, resources, and priorities among local governments within the operational area and serves as the coordination and communication link between the local government level and the regional level. (4) "Regional level" manages and coordinates information and resources among operational areas within the mutual aid region designated pursuant to Government Code§8600 and between the operational areas and the state level.This level along with the state level coordinates overall state agency support for emergency response activities. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 16 Page 80 of 315 TDPUD regularly coordinates and communicates with the relevant safety agencies and other relevant local and state agencies. TDPUD understand the role of SEMS in emergency communications and follows the Town of Truckee, Nevada County, and Placer County, which are the local leads for emergency operations and disaster response. TDPUD, as a small utility, has not historically had a formal risk management position but due to emerging needs recently added a risk and compliance position. More formally implementing SEMS is a priority for 2023. Under the SEMS structure, a significant amount of preparation is done through advanced planning at the county level, including the coordination of effort of public, private, and nonprofit organizations. Generally, the majority of TDPUD's service territory resides in Nevada County. Nevada County serves as the operational area, which is guided by the Operational Area Emergency Service Council (Nevada County) and is headed by the Chairman of the Board of Supervisors (or designee). The operational area includes local and regional organizations that bring relevant expertise to the wildfire prevention and recovery planning process. These participants include: • Office of Emergency Services Program Manager, Nevada County, Paul Cummings (paul.cummings@co.nevada.ca.us, 530.265.1515) • City of Nevada City (or designee) • City of Grass Valley (or designee) • Town of Truckee (or designee) • Nevada Irrigation District (or designee) • Nevada County Fire Chief's Association (or designee) • Nevada County Sheriff (or designee) • American Red Cross (or designee) • Tahoe National Forest (or designee) • California Department of Forestry and Fire Protection (CAL FIRE; or designee) • Tahoe Forest Hospital District (or designee) • Pacific Gas and Electric Company (or designee) • Nevada County Public Health Administrator (or designee) • Placer County Public Health Administrator (or designee) • Others that the Operational Area Emergency Service Council requests be in attendance Additionally, a small portion of TDPUD's service territory resides in Placer County, overseen by the Placer County Office of Emergency Services Council. The Placer County Office of Emergency Services' operational area includes local and regional organizations that bring relevant expertise to the wildfire prevention and recovery planning process. TDPUD staff play a formal role in emergency response through the local lead agency (either Town of Truckee, Nevada County, (5) "State level" manages state resources in response to the emergency needs of the other levels, manages and coordinates mutual aid among the mutual aid regions and between the regional level and state level,and serves as the coordination and communication link with the federal disaster response system. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 17 Page 81 of 315 or Placer County).TDPUD will staff an Emergency Operations Center upon request and fits into the Utilities Unit of the Emergency Operations Center (note: Truckee is serviced by multiple electric utilities). TDPUD also works directly with its public safety partners on a daily basis in responding to outages, fire, accidents, and a wide-variety of emergencies. The Town of Truckee has an adopted Emergency Operations Plan that is periodically updated and can be found at this link: https://bof.fire.ca.aov/media/420iskxo/rr)c-2-b-iv-town-of-truckee-emer_ eq ncy- operations-plan-supplemental.pdf. TDPUD is a member of the California Utilities Emergency Association, which plays a key role in ensuring communications between utilities and emergency responders during emergencies. TDPUD also participates in the Western Energy Institute's Western Region Mutual Assistance Agreement, which is a mutual assistance agreement covering utilities across a number of western states. In addition to those agreements, TDPUD is also signatory to the American Public Power Association mutual aid agreement, providing nationwide access to resources for system restoration and support after a major event that exhausts TDPUD resources. It should be noted that TDPUD's service territory is largely within the Town of Truckee boundaries but does include unincorporated areas of Placer and Nevada Counties. The Town of Truckee did not formally incorporate until the 1990s, leaving more than a dozen local governmental agencies covering utilities, fire, and other critical local functions. Each local agency, when it comes to emergency response, is aware of their role and responsibility with overall management and communication strictly controlled by the appropriate town/county/state/federal emergency response agency through the Emergency Operations Center. A. PARTICULAR RISKS AND DRIVERS ASSOCIATED WITH DESIGN, CONSTRUCTION, OPERATION, AND MAINTENANCE TDPUD designs and constructs its electric facilities to meet or exceed the relevant federal, state, or industry standard. TDPUD treats California Public Utilities Commission (CPUC) General Order (GO) 95 as a key industry standard for design and construction standards for overhead electrical facilities and, as such, meets or exceeds all applicable standards in GO 95. Additionally, TDPUD monitors and follows as appropriate the National Electric Safety Code. Risk drivers associated with design, construction, operations, and maintenance within TDPUD's 45-square-mile service territory include: • Expulsion fuses still in use in portions of the TDPUD service territory • Utility poles reaching the end of the service life • Combustible poles in the High Fire Threat District (HFTD) • Limited staff and equipment 134.7 miles of overhead distribution wires; 64% of overhead wires are in a HFTD • Overhead circuits in areas with poor road access Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 18 Page 82 of 315 B. PARTICULAR RISKS AND RISK DRIVERS ASSOCIATED WITH TOPOGRAPHICAL AND CLIMATOLOGICAL RISK FACTORS The TDPUD service territory is located between 6,000 and 8,000 feet elevation on the eastern slope of the Sierra Nevada Mountain Chain near Lake Tahoe. The TDPUD service territory experiences the most severe weather during the winter where severe storms can bring damaging levels of snow and/or rain and extreme winds (80++ mph). During the fire season, the Truckee area experiences fast-moving, low-pressure systems that bring high winds and dry lightning to the TDPUD service territory. Within the TDPUD service territory and the surrounding areas, the primary risk drivers associated with topographical or climatological for wildfires include: • Overhead circuits traverse mountainous areas of mixed conifer forests with continuous surface fuels, including annual grasses, herbaceous vegetation,and patches of woody shrubs. • Overhead circuits traverse areas of steep slopes. Several circuits are on slopes or in canyons aligned with the prevailing winds (Interstate 80 corridor). • Summertime precipitation in the area occurs in the form of afternoon thunderstorms; along with these storms may come dry lightning with very little precipitation. • Prevailing winds align with the Interstate 80 corridor resulting in strong winds through the center of the TDPUD service territory. CLIMATE CHANGE Truckee has warmed an average of 2.0°F over the last 80 years when comparing the historical 30-year period (1937-1966) and the recent 30-year period (1987-2016). There are now eight fewer days per year below freezing, and the number of days above 90°F has increased by 10 days per year. Average snowfall has declined by 15%. All these changes have occurred from a 2.0°F temperature increase. If greenhouse gas emissions continue at current levels globally, then Truckee's average temperatures are expected to warm by 5-7°F by the 2050s and 8-11°F by the 2080s. By the 2080s, April snowpack could be reduced by 84%to 96%. However, if emissions are significantly reduced in the near term, then warming could level off in the 2050s (Town of Truckee Planning Division 2020). It is expected that by mid-century the TDPUD service territory will experience: • A 55%-68% reduction of days below freezing per year • A 68%-71% reduction of April snowpack • A 31%-51% increase in drought stress • Up to 31 more days above 90°F • Up to 61% more acres burned per year by wildfire C. ENTERPRISE-WIDE SAFETY RISKS Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 19 Page 83 of 315 TDPUD uses a methodical approach to address/mitigate enterprise safety risks. This approach utilizes both risk assessment and intimate knowledge of its operational practices. Risk assessment is a process to identify and manage potential risks that could undermine core business functions, threaten business continuity, or impact recover. Risk assessment will be used to analyze safety risks, which include: • Pole Replacement Ranking Tool (Appendix C) • Unavailability of NV Energy's transmission because of an outage or planned Public Safety Outage Management (PSOM) de-energization event due to existing wildfire • Interconnection and distribution interconnection (Glenshire) • Unavailability of California Pacific Electric Company/Liberty Utilities' alternate distribution feed (Glenshire) • Loss of internet connectivity • Loss of radio communications • Loss of cellular communications • Impacts of system de-energization • Impacted roadways limiting movement of personnel and equipment D. CHANGES TO THE CPUC FIRE THREAT MAP As part of the development of the 2023 WMP, TDPUD reviewed the conditions present in its territory, including the current extent of the HFTD. TDPUD does not recommend any changes to the CPUC state-wide Fire Threat Map. A. HIGH FIRE THREAT MAP FOR TDPUD TDPUD participated in the development of the CPUC Fire Threat Map,4 which designates the HFTDs across California. In the map development process, TDPUD served as a territory lead and worked with CAL FIRE, CPUC staff, and local fire officials to identify areas of the TDPUD service territory that are at an elevated or extreme risk of power line-ignited wildfire. TDPUD incorporated the HFTD mapping into its construction, inspection, operation, maintenance, repair, and vegetation management practices. The fire threat areas, as designated by both CAL FIRE and CPUC, have been incorporated into the TDPUD geographic information system (GIS) to overlay with TDPUD water and electric facilities and identify any infrastructure within areas of high fire threat. 4 Adopted by CPUC Decision 17-12-024. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 20 Page 84 of 315 For the purpose of the WMP and to retain consistency, TDPUD treats its entire service territory as Tier 3 high fire threat. B WEATHER MONITORING The TDPUD service territory covers a relatively small section of the Truckee watershed. Local, state, and national sources provide accurate and comprehensive weather information for the TDPUD service territory. Variations in weather due to terrain or microclimates are often well known by TDPUD staff. TDPUD monitors current and forecasted weather data from a variety of sources including: • U.S. National Weather Service-Truckee Donner Remote Automatic Weather Station (TADC1) and the Truckee Airport • U.S. Forest Service Wildland Fire Assessment System • Northern California Geographic Area Coordination Center-Predictive Services Fire Weather/Fire Danger Outlooks for Region NC07 (Northern Sierras) • Internal knowledge of local conditions • Local weather data from NV Energy and Liberty Utilities automated weather stations Each day, TDPUD will assign one of four operating conditions based on the relevant weather data and knowledge of local conditions: (1) Normal: During normal conditions, no changes are made to operations or work procedures. (2) Elevated: During elevated fire-risk conditions, TDPUD staff will perform normal work with an elevated level of observation for environmental factors that could lead to an ignition. (3) Extreme: During extreme fire-risk conditions, TDPUD may delay routine work on energized primary lines (12.47 kV and 14.4 kV). TDPUD may perform necessary work to preserve facilities or property. Extreme weather is defined as weather phenomena that are at the extremes of the historical distribution and are rare for a particular place and/or time, especially severe or unseasonal weather. Such extremes include severe thunderstorms, severe snowstorms, ice storms, blizzards, flooding, high winds, or heat waves. (4) Red Flag: The National Weather Service issues Red Flag Warnings (RFWs) and Fire Weather Watches to alert fire departments of the onset, or possible onset, of critical weather and dry conditions that could lead to rapid or dramatic increases in wildfire activity.5 An RFW is issued for weather events that may result in extreme fire behavior that will occur within 24 hours. An RFW is the highest alert. While an RFW is in effect, TDPUD's crews limit hot-work, such as welding, grinding, and cutting, and TDPUD will delay all routine work on energized primary lines (12.47 kV and 14.4 kV). TDPUD may perform necessary work to preserve facilities or property. Vegetation management and line crews have on-site fire suppression equipment and conduct tailboard meetings to confirm the location and readiness of the fire suppression equipment. 5 http://www.fire.ca.gov/programs/communications/red-flag-warnings-fire-weather-watches/ Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 21 Page 85 of 315 C. DESIGN AND CONSTRUCTION STANDARDS TDPUD electric facilities are designed and constructed to meet relevant federal, state, and industry standards. TDPUD treats GO 95 as a guiding standard for design and construction of overhead electrical facilities. TDPUD meets all standards in GO 95 and constructs its facilities consistent with the "heavy-loading" district as defined by the CPUC. TDPUD's overhead electric system is designed to withstand severe winter storms, including extreme wind and snow events. Winds during severe winter storms generally exceed the wind speeds that the TDPUD service territory experiences during RFWs. As a result of this approach, TDPUD's system is hardened and more resilient to extreme weather events such as high winds. As stated above, TDPUD's electric facilities are designed to meet GO 95 for design, construction, and maintenance. While TDPUD may choose to exceed the standard based on local conditions and/or knowledge, the minimum requirement is to meet the standard over the duration of the action. Where review/inspection shows that the minimum standard is not sufficient to maintain compliance, TDPUD adapts accordingly. In addition to meeting the GO 95 standards, TDPUD is making the following upgrades to its facilities and equipment to reduce the risk that its equipment will start a wildfire. POLE REPLACEMENT PROGRAM TDPUD has an ongoing pole replacement program that prioritizes poles for replacement based on three factors: age; conditions; and the impact an event on a given pole could have on safety, reliability, and compliance. As part of this program, TDPUD poles are inspected on a regular basis and scored based on the three factors. Pole scores are recorded in the TDPUD GIS system. Poles with the highest score are prioritized for replacement. Appendix C contains a detailed description of the pole replacement ranking tool used by TDPUD. In 2022, TDPUD replaced 14 poles requiring attention based on previous years' intrusive pole inspections. In addition, TDPUD replaced numerous poles as part of re-conductor projects and installed a new overhead conductor. NON-EXPULSION CURRENT LIMITING FUSES Since 2019, TDPUD has been evaluating the suitability of non-expulsion or current limiting fuses on its overhead system. In locations where the expulsive fuses have been determined to present a risk of starting a wildfire, TDPUD has been replacing the expulsive fuses with non-expulsive fuses. TDPUD selected Eaton's Cooper Power Systems full-range, current-limiting, dropout Energy Limiting Fuse (ELF) for the pilot project. The ELF fuse has been granted permanent exemption by CAL FIRE from pole clearance requirements as specifically listed in Title 14 of the California Code of Regulations, Section 1255.10. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 22 Page 86 of 315 All in-line and transformer fuse locations where an ELF fuse has been installed are tracked in the GIS and tagged with ELF identifier. This allows TDPUD to track and report any outage or hazard occurrences on ELF fuses through TDPUD's Responder Outage Management System (OMS). This program began in early 2019. Staff completed the evaluation of the ELF fuses, validating and confirming their suitability and effectiveness for TDPUD's electric system. Beginning 2021, TDPUD staff implemented a 3-year capital improvement project and funding to replace all overhead fuses in the distribution system with ELF fuses and non-load break cutouts. In February of 2021, TDPUD staff were notified by Eaton of an ELF fuse recall due to a failed manufacturer process. This resulted in TDPUD staff having to inspect all fuses installed and replace suspect fuses. This recall was further hindered by material shortages and ongoing procurement delays. In 2022, TDPUD was not able to progress on the ELF fuse deployment project after completing efforts to address a manufacturer recall issued in 2021. The ELF deployment project is planned to resume in 2023. FR3 INSULATING FLUID TDPUD switched exclusively to FR3 dielectric insulating fluid in 2008. FR3 has an extremely high flashpoint in excess of two times that of its traditional mineral oil counterpart (360°C versus 160°C). It is now a requirement for all new oil-insulated equipment, including transformers (pole- bolted and pad-mounted), substation transformers, and substation voltage regulators. TDPUD staff continue to evaluate the appropriateness of FR3 insulating fluid in its future procurement of pad-mounted switchgear. COVERED PRIMARY JUMPER WIRE TDPUD is implementing the use of covered (i.e., tree wire) primary jumper wire in place of bare wire. Primary jumpers are used to connect transformers, underground risers, and fuse cutouts to main overhead circuit conductors. The use of covered primary jumper wires helps to minimize unintentional contact with wildlife and windblown debris. PROPOSED SERVICE REQUIREMENTS Since 1995, TDPUD code has required all new or reconstructed developments to take service from TDPUD via an underground system; however, limited exceptions exist in current TDPUD code for some single-family residences. TDPUD seeks to minimize the installation of overhead power lines where practicable and will, therefore, recommend an underground requirement for all electric services and considers the following: • All new installations will be required to take service from an underground source. • Like-for-like panel replacements will be required to convert to underground service. • Upgraded panel replacements will be required to convert to underground service. • TDPUD will not attach to trees for any reason. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 23 Page 87 of 315 • TDPUD may consider a cost-sharing program for customers that desire to convert an existing overhead service to an underground service. • Customer(s) receiving service via legacy tree attachment(s) will be required to comply with Section 5.36, Tree Attachments. TREE ATTACHMENTS (LEGACY ATTACHMENTS) Existing tree attachment service drops are tracked within the GIS to identify locations where trees and branches may be a potential hazard to electric infrastructure and to provide TDPUD crews with location information for inspecting tree attachments. Legacy tree attachments are no longer allowed. When an existing tree attachment fails or is damaged, a new utility pole is installed and used for securing all secondary attachments. Pursuant to Title 14 of the California Code of Regulations Section 1257, and annually starting in 2020, contract tree crews are trimming the area of the attachments and performing an inspection. Any hazard found is immediately reported to TDPUD staff for mitigation. TDPUD monitors trends in materials, technology, and work methods to evaluate prudent operational changes to enhance the efficacy of wildfire mitigation. These evaluations include: • Engineering pole-ranking tools • Intrusive pole inspections • New construction methods/materials • Undergrounding new construction and tree wire (covered wire) use, where applicable ADVANCED METERING INFRASTRUCTURE TDPUD has invested in and deployed advanced metering infrastructure (AMI) across the entire service territory. AMI is an integrated system of smart meters, communications networks, and data management systems that enable two-way communication between utilities and customers. The system provides several important functions that were not previously possible or had to be performed manually, such as the ability to automatically send an outage notification to TDPUD's OMS, automatically and remotely measure electricity use, connect and disconnect services, detect tampering, identify and isolate outages, and monitor voltages. In 2021, TDPUD implemented the National Information Solutions Cooperative (NISC) Operational Analytics module for the electric utility. The Operational Analytics module is an enhancement to the existing Meter Data Management System used by TDPUD to gather interval data across all AMI meters. The Operational Analytics module has improved TDPUD's operational efficiencies and grid reliability through advanced data analysis. The implementation included integrations with TDPUD's AMI, Esri GIS, and Supervisory Control and Data Acquisition (SCADA) systems that are now used to proactively locate and replace critically overloaded or underloaded transformers and reduce feeder losses. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 24 Page 88 of 315 OUTAGE MANAGEMENT SYSTEM Since 2007, TDPUD has utilized Schneider Electric's Responder OMS within the GIS for tracking and responding to electric outages and system hazards. The OMS automatically captures outage information in real time from all AMI meters and captures incoming phone calls from the public and TDPUD customers. The OMS very quickly consolidates field events and alerts staff to potential issues impacting the electric system. In 2019, TDPUD extended categorizing incidents to include fires, hazard trees, or branches in proximity of electric lines. The wires down category has been tracked since the program's inception in 2007. In addition to tracking active hazards to the system, all calls entered into the OMS can later be used for reporting based on outage cause, duration, system device, and number of customers affected. This information is used by TDPUD engineers to plan electric system upgrades and device replacements. Events recorded in the OMS are stored in the Responder archives, available for engineering and operations staff upon request, and made available to public agencies as part of yearly CPUC reporting requirements on reliability indices. In 2021, TDPUD's Board authorized a contract for a new OMS available through NISC. TDPUD utilizes NISC software as the base enterprise planning resource software that manages TDPUD's accounting, payroll, and customer information systems. TDPUD has standardized this software for the past 18 years due to in-house expertise with the product, the advanced leadership of NISC with other public power utilities, and its compatibility with other TDPUD products including the AMI, Esri GIS, and SCADA systems. The new NISC OMS has improved upon the existing Schneider OMS by simultaneously informing TDPUD on how to best resolve an outage while automatically communicating with customers that they are experiencing an outage and providing any available information on how the outage is being resolved. NISC's OMS uses a prediction engine that integrates with TDPUD's AMI, Esri GIS, and SCADA systems to accurately locate the source of the outage. The OMS also includes an interactive map with active locations of crews in the field responding to an incident. A reporting platform is also available that provides service and quality industry reports on the electric system including CPUC reporting requirements and reliability indices. TDPUD customer's will be able to customize outage alerts through the NISC MyAccount/SmartHub customer engagement tool. SUPERVISORY CONTROL AND DATA ACQUISITION TDPUD has invested in a robust fiber-based SCADA system that provides staff the capability to operate the substation reclosers on supervisory control from the TDPUD office or remotely through a secure virtual private network (VPN) connection. TDPUD is investigating an upgrade to the system to allow for supervisory control of all critical field reclosers, a function that is currently unavailable. This function would allow TDPUD staff to remotely enable or disable all recloser settings, including setting all reclosers to non-reclose Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 25 Page 89 of 315 mode (i.e., one-shot operation) annually as needed to minimize the risk of fires caused by arcing or faults. Currently, TDPUD needs to manually place these reclosers on non-reclose. D. VEGETATION MANAGEMENT TDPUD has a developed a comprehensive vegetation management program for maintaining vegetation near its facilities and circuits. TDPUD's vegetation management program is described in detail in its Vegetation Management Plan (VMP) that is attached to this WMP in Appendix D. In addition to maintaining the statutory requirements for clearance around high voltage wires, TDPUD's VMP prescribes a treatment for a 20-foot right-of-way on all sides of its utility poles. Within this easement, all dead vegetation, including dead trees and shrubs, is removed and surface vegetation is maintained to minimize the accumulation of surface fuels. TDPUD vegetation management staff identify standing dead trees within 200 feet of high-voltage wires regardless of ownership and will seek permission to remove any dead tree within this area that has the potential to strike TDPUD wires. In the current version of the VMP, TDPUD's tree-trimming program is on a 5-year tree-trimming cycle because the majority of the trees near TDPUD lines are mature conifers with compact crowns compared to hardwood trees. These trees have relatively low growth rates and do not respond with rapid shoot growth. Dead vegetation in the right-of-way and dead trees that threaten the wires are treated on an as-needed basis. As part of TDPUD's VMP, contractors and internal TDPUD staff are equipped with TDPUD-provided mobile devices to record the location and dates of vegetation management-related activities. Vegetation management generally consists of removing, cutting, trimming, and clearing away of trees, tops, limbs, branches, bushes, vines, and foliage, and the removal of hazard trees and inspection of legacy tree attachments in proximity to TDPUD electrical lines, stations, and property within public utility easements. All tree-trimming inspection records are stored in TDPUD's GIS and are used for reporting yearly tree-trimming progress and planning future tree- trimming routes and locations. In addition to planned tree trimming, the TDPUD customer information system also records customer calls regarding concern for potential tree hazards in proximity to electric lines. Service orders are created for crews to respond to and correct hazard tree reports, as well as record the outcome of the hazard. This information can also be used for reporting the number of customer calls regarding hazard trees, number of hazard tree removals, and number of occurrences by location. This program began in 2005 and, continuing for 2023, TDPUD will be on a 5-year cutting cycle and will adjust as needed. It should be noted that TDPUD removes dead or dying vegetation within the vegetation management area. Given the high mountain environment and relatively short growing season, TDPUD has not had problems with treatment areas being replaced with fast-growing grasses or invasive species. TDPUD uses minimal or no herbicides while conducting vegetation management. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 26 Page 90 of 315 E. INSPECTIONS TDPUD meets the minimum inspection requirements provided in CPUC GO 165, Table 1 and CPUC GO 95, Rule 18. Pursuant to these rules, TDPUD inspects electric facilities in the HFTD areas more frequently than its counterparts in non-HFTD areas. Additionally, TDPUD staff use their knowledge of the specific environmental and geographical conditions to determine when areas may require more frequent inspections and/or mitigations. TDPUD utilizes GO 95 and GO 165 as its guiding documents as part of a robust asset management/maintenance program. TDPUD's GIS contains records for electric system inspections performed as part of the GO inspection program. TDPUD crews are equipped with mobile devices with access to TDPUD's GIS data to record inspections and report any potential issues to be corrected. Beginning in 2019, this inspection program was extended to capture potential tree hazards in proximity to electric infrastructure. Corrections and repairs to the system are also recorded as part of this program, and data are available to TDPUD's engineering and operations staff to plan repairs and upgrades to the electric system. TDPUD's goal is to ensure that all inspections performed within its service territory are complete before the beginning of the historical fire season, typically by June 1. TDPUD monitors drought conditions and other relevant factors throughout the year to determine if inspections should be completed on an adjusted timeline. If TDPUD staff discovers a facility in need of repair that is owned by an entity other than TDPUD, TDPUD will notify the facility owner in writing and also notify the agency having jurisdiction. F. WORKFORCE TRAINING TDPUD has developed rules and complementary training programs for its workforce to reduce the likelihood of an ignition. All field staff are trained annually in the following areas: in the content of the WMP; in proper use and storage of fire extinguishers; in required pre-job briefings to discuss the potential(s) for ignition and environmental conditions (current and forecasted weather that coincides with the duration of work for the day); and in identifying the closest fire extinguisher. TDPUD staff are also active in electric utility joint-action groups, such as the California Municipal Utilities Association, Northern California Power Agency, Utah Associated Municipal Power Systems, and the American Public Power Association, to leverage the industries' collective experience and to take advantage of training and other workforce development activities. G. RECLOSER POLICY During fire season, TDPUD disables all automatic reclosing function for all automatic circuit reclosers (ACRs or reclosers) on its system (i.e., one-shot operation). This ensures there will be no automatic circuit reclosing during the fire season. Fire season is typically defined as June 1 st Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 27 Page 91 of 315 through October 31 st but may be extended based on actual fire danger and environmental impacts due to climate change. Operational needs may change due to extended/early winter conditions within the service territory of TDPUD. During these types of weather events the Electric Utility Director or their designee may suspend the summer one-shot operation practice and return the automatic system reclosers to normal operation. In the event there is a lack of winter precipitation due to climate change, reclosers may be placed on one shot early ahead of the summer months due to the dry conditions. H. DE-ENERGIZATION TDPUD, in consultation with other Publicly Owned Utilities (POU) and TDPUD water utility staff and in communication with key local agencies, has evaluated the efficacy of a Public Safety Power Shutdown (PSPS) type of de-energization program. Major considerations included: • TDPUD heavy-loading construction standards that are hardened to withstand high wind, snow loading, and ice formation • The offset between when TDPUD's overhead electric distribution system experiences its most severe weather threats (i.e., severe winter storm[s]) and the weather conditions during red- flag warnings (i.e., typically in late summer/fall with only moderate weather threats) • The potential negative impacts to fire response, water supply, public safety, and emergency communications should a fire occur while TDPUD de-energized a portion or all its system • Potential loss of water supply to fight wildfires due to loss of production wells and pumping facilities • Negative impacts to emergency response and public safety due to the historical disruptions in internet and cell phone service during periods of extended power outages • The loss of key community infrastructure and operational efficiency that occurs during power outages Based on the above considerations, the risks of implementing a PSPS-type program seem to far outweigh the chances that TDPUD's electric overhead distribution system would cause a catastrophic wildfire. TDPUD, on a case-by-case basis, has historically and will continue to consider de-energizing a portion of its system in response to a known public safety issue or in response to a request from an outside emergency management/response agency. Any de-energizing will be performed in coordination with TDPUD water utility staff and key local partner agencies. TDPUD will also monitor the evolution of PSPS implementation by other California electric utilities to continue to refine its evaluation of this important topic. While TDPUD has not implemented a PSPS-type program for its system, TDPUD is a transmission- dependent utility of NV Energy that, shortly after TDPUD adopted the original WMP, announced Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 28 Page 92 of 315 its own de-energizing program (PSOM)6. NV Energy originally included TDPUD's service territory in its original program, later removed TDPUD's service territory from the program for the 2019 and 2020 fire seasons, and then included TDPUD's service territory again in the program for the 2021 fire season. It is again possible that, during extreme fire danger, TDPUD could experience a system-wide outage due to a loss of transmission from NV Energy, which will likely be from a PSOM event. As a result, TDPUD, and other key local agencies, held a series of meetings with NV Energy in 2019, 2021, and 2022 to fully understand the conditions under which NV Energy would de- energize transmission and to develop communication protocols so that NV Energy could notify TDPUD and then TDPUD could notify key agencies and its customers. These meetings will continue into 2023. IMPACTS TO PUBLIC SAFETY The TDPUD service territory includes seven Truckee Fire Protection District stations, a CAL FIRE facility at the Truckee Tahoe Airport, one hospital, and three police stations. TDPUD does not generate electricity locally and its sole source of power comes from NV Energy transmission. In the event of a power outage or a NV Energy-initiated PSOM, first responders would be reliant on backup generators for power. The seven fire stations, CAL FIRE facility, three police stations, and the hospital all have backup generators that can supply electricity to their facilities in the event of power shutdown. Truckee residents in general are accustomed to adverse conditions including extreme weather that shuts down public transportation and services. Many of TDPUD's customers have backup generators installed at their properties and TDPUD encourages customers to be prepared for a PSOM event with several informational postings on its website, including generator safety and the installation of permanently installed backup generators. CUSTOMER NOTIFICATION PROTOCOLS TDPUD has developed a list of critical agencies/emergency responders with a commitment to make direct contact should NV Energy announce a potential PSOM event. If TDPUD gets notified of a pending PSOM event, then TDPUD staff will contact local emergency responders and the hospital by phone, text, and/or email using all channels until contact and message receipt are confirmed. Customers are notified of wildfire alerts, related outages, potential PSOM outages, relay setting outages, and re-energizations using contact information in their customer accounts and by signing up for individual alerts through the customer engagement tool (MyAccount/SmartHub). Customer notification is achieved through several channels including text alerts and email alerts. The methods for customer notification are based on the extent of the outage with customer alerts through the OMS and the website outage map in real-time. During limited outages, TDPUD 6 www.NVenergy.com/safety/PSOM Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 29 Page 93 of 315 may only use its website and automated customer notifications through the OMS. For more significant outages, TDPUD will use social media and the website emergency banner to notify customers of an outage and provide updates when available. Major transmission and system- wide outages would also include Nixle alerts and coordination with Code Red posts. Non-customers can sign up for Nixle alerts for major outages, including NV Energy PSOM outages, by texting "TDPUD" to 3331 1 1. TDPUD also posts information regarding emergencies on its website and on several social media outlets such as Twitter and Facebook. An online outage map is available for more information about emergencies and outages in TDPUD. The website also includes information and links to sign up for email and text alerts. To help TDPUD's customers and community be aware and prepared for NV Energy PSOM wildfire safety transmission power outages, TDPUD has spent significant time and resources to communicate both the timing of a PSOM outage along with the expected start of restoration. COMMUNITY OUTREACH TDPUD has extensive relationships across all organizations in the community. These relationships include direct interactions with the agencies directly responsible for fighting fires (Truckee Fire Protection District and CAL FIRE), agencies leading emergency response efforts (Town of Truckee, Nevada County, and Placer County), and key public and private landowners (U.S. Forest Service, California State Parks, Tahoe Donner Association, Tahoe-Truckee Airport District, etc.). TDPUD staff regularly provide information to these agencies including updates on fire, vegetation management requirements, and TDPUD programs. TDPUD also works closely with our partners and considers key planning and other documents in implementing this WMP. This includes the Truckee Fire Protection District's Community Wildfire Protection plan and the Town of Truckee's Right of Way clearing program and other emergency response activities. As the local electric and water utility, TDPUD has robust community outreach and marketing programs to effectively communicate with its customers and community. The agendas for all TDPUD Board meetings are publicly available and the meetings are open for the public to attend. The regularly scheduled Board meetings are also broadcast locally from TDPUD's website (www.tdpud.org) and archived on TDPUD's website for access after the meeting. TDPUD is active in the community, typically attending dozens of community events each year, including Truckee Day, Truckee Thursdays, Tahoe Truckee Earth Day, Truckee Home Show, Truckee Cleanup Day, and Big Truck Day. TDPUD staffs booths, has staff available to interact with the community, and delivers energy, water, and customer programs directly to its customers. TDPUD provides information on its Vegetation Management Program, performs free de- energizing of customers' overhead service connections to allow them to clear defensible space while working safely, and educates the community on TDPUD's overall efforts to respond to catastrophic wildfires. TDPUD intends to continue this effective engagement in the future. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 30 Page 94 of 315 TDPUD also has robust marketing and communication efforts leveraging its website (www.tdpud.org), social media (Facebook/Twitter/Instagram), print ads, and digital marketing. TDPUD is a regular advertiser in the Sierra Sun, Moonshine Ink, Truckee Chamber of Commerce, Tahoe Donner News, and The Shire, as well as on KTKE 101.5 local radio. In addition, TDPUD has an informative customer lobby with ready access to customer service representatives, extensive digital media to educate customers, and engaging displays. Specific to wildfire-related community outreach, TDPUD has been very active promoting the Vegetation Management Program, including regulatory changes increasing the vegetation clearances and vegetation management practices. TDPUD also engages in direct communication with property owners for quick resolution of any concerns or disputes. TDPUD has information on the website, social media, digital media, print advertising, and radio. TDPUD has worked with Tahoe Donner Association, which is in a Tier 3 area and has almost half of TDPUD's residential connections, to include an extensive article in the monthly Tahoe Donner News regarding fire, vegetation management, and everyone doing their part. Although TDPUD does not have a PSPS-type operational practice, it may de-energize a portion or all the overhead electric system for one of the following reasons: • If an outside emergency management/emergency response agency requests a power shutdown • If TDPUD elects to de-energize segments of its system due to extreme weather or other safety considerations • As a result of a NV Energy PSOM event or transmission outage If TDPUD experiences an outage during wildfire season, staff will patrol the affected portions of the system before the system is re-energized. Suspect equipment or distribution lines that cannot be patrolled will remain de-energized. In addition, system performance abnormalities will be monitored via TDPUD's SCADA system and its AMI/OMS systems. In addition, TDPUD participates with the California Emergency Management Agency (also known as the California Governor's Office of Emergency Services) and California Utilities Emergency Association. The California Emergency Management Agency is responsible for overseeing and coordinating emergency preparedness, response, recovery, and homeland security activities, while the California Utilities Emergency Association serves as a point-of- contact for critical infrastructure utilities and the California Governor's Office of Emergency Services to facilitate communications, provide emergency response, and support emergency planning, mitigation, training, exercises, and education. NV Energy provides TDPUD with advance notification of PSOM events. TDPUD does not generate power locally and is dependent on NV Energy for transmission of electricity. NV Energy has a wildfire safety de-energization program (PSOM) where, based on Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 31 Page 95 of 315 catastrophic wildfire risk, NV Energy will de-energize transmission lines that deliver power to Truckee. TDPUD has tested and implemented a re-energization protocol in preparation for a system-wide wildfire safety power outage based on NV Energy's current PSOM transmission de- energization program. TDPUD staff worked in close collaboration with NV Energy to establish communication protocols for NV Energy to communicate the end of the extreme wildfire danger and to coordinate the timing of NV Energy's transmission system visual inspections/re- energization and TDPUD's entire distribution system visual inspection/re-energization. Both NV Energy and TDPUD are committed to restoring power as quickly and safely as possible. VIII. EVALUATING THE PLAN A. METRICS AND ASSUMPTIONS FOR MEASURING PLAN PERFORMANCE TDPUD has historically tracked two metrics to measure the performance of the WMP over the entire year. Starting in 2022, TDPUD is only tracking these metrics during fire season (defined as June through October) since winter outages occur when there is no wildfire danger: 1. Number of fire ignitions 2. Wire-down events within the service territory 3. Outage Causes Metric 1: Fire Ignitions For purposes of this metric, a fire ignition is defined as follows: • TDPUD's electrical infrastructure was associated with the fire. • The fire was self-propagating and of a material other than electrical. • The resulting fire traveled greater than one linear meter from the ignition point. • TDPUD has knowledge that the fire occurred. To evaluate this metric, TDPUD reports the number of fires that occurred that were less than 10 acres in size. Any fires greater than 10 acres will be individually described. New fire ignitions will be reported to management and firefighting agencies. In 2022,TDPUD recorded zero new fire ignitions caused by TDPUD's electrical facilities or equipment. Metric 2: Wire-Down Events The second metric is the number of wire-down events within TDPUD's service territory. For purposes of this metric, a wire-down event includes any instance where a primary distribution conductor falls to the ground or onto a foreign object, which is defined as any object not specifically an asset of TDPUD (i.e., phone, cable, trees, etc.). Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 32 Page 96 of 315 TDPUD will not normalize this metric by excluding unusual events (i.e., severe storms, car versus pole incidents, or snow unloading). However, TDPUD will supplement this metric with a qualitative description of any such unusual events. In 2022, TDPUD recorded no wire down events. Metric 3: Outage Causes The third metric used is the number of outages recorded by the month the outage occurred and categorized by cause. This is a new metric for 2022 and was enabled by TDPUD's new OMS. Outage information is collected from the data recorded and stored by the OMS. For the purpose of this metric, TDPUD is defining an outage as an event when a transmission line or electrical equipment is out of service and the event is recorded in the OMS as an outage. In 2022 from June through October, TDPUD recorded 309 outages; 113 were of unknown origin, 107 of these outages were due to planned events (maintenance, construction, etc.), 36 were caused by animals 19 were caused by equipment failure, and 4 outages were caused by vegetation. The remaining 30 outages had a variety of causes including vehicle impacts and outages caused by the public. B. IMPACTS OF METRICS ON THE PLAN New fire ignitions and wire-down events have been used as the metrics of the TDPUD WMP since the initial Plan was drafted in 2019. As part of the annual WMP review process, TDPUD reviews the data collected for each metric and continues to update the WMP annually. The two metrics have proven to be useful for informing the effectiveness of the WMP particularly when complemented by additional data such as location for new fire ignitions and data from the OMS (location, customers impacted, etc.) for wire-down events. TDPUD uses the data obtained for both metrics with the additional data to pinpoint locations where additional wildfire prevention is needed, including where additional vegetation management treatments are necessary and where TDPUD needs to install more animal deterrents. C. MONITORING AND AUDITING THE PLAN Internally, the wildfire prevention strategies and programs described in the WMP are evaluated on an ongoing basis. TDPUD staff tracks the utility's progress in completing wildfire prevention program goals. The progress data and data regarding the metrics plus outage information are reviewed by the Electric Utility Director. The Electric Utility Director, or designee, will, at least on a semi-annual basis, update the General Manager regarding the Plan's implementation, identified deficiencies, or recommendations for updating. Any critical or immediate concerns will be brought to TDPUD's Board of Directors. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 33 Page 97 of 315 In addition to the ongoing internal review, TDPUD presents the current WMP to its Board of Directors for review on an annual basis in a public setting with agendized materials. Development of the Plan, along with the updates, is done collaboratively with the local emergency response and fire agency. D. IDENTIFYING AND CORRECTING DEFICIENCIES IN THE PLAN TDPUD staff have the role of vetting current procedures and recommending changes or enhancements to build upon non-optimized strategies in the Plan.TDPUD staff utilizes the data (e.g., progress in completing prevention tasks) obtained during the ongoing review of its wildfire prevention programs to identify areas where additional work is needed, such as increasing clearance between wires and adjacent vegetation or removing dead trees, or areas where system upgrades need to be prioritized, such as pole replacement or the installation of animal deterrents. The Electric Utility Director, or their designee,will be responsible for spearheading discussions on correcting deficiencies when updating the Plan for its annual presentation to the Board.This is done in collaboration with sister utilities and joint-action groups such as the California Municipal Utilities Association, Northern California Power Agency, and Southern California Public Power Authority. All stakeholders are empowered to suggest improvement opportunities, including, but not limited to, field crews, management, auditors,fire safety professionals, and members of the public. E. MONITORING THE EFFECTIVENESS OF INSPECTIONS TDPUD currently utilizes GO 95 and GO 165, respectively, as its guide to inspect its system. Field staff routinely patrol the service territory and correct deficiencies as they are encountered. TDPUD tracks deficiencies that are repaired upon discovery within its GIS and consistent with the guidelines of GO 95 and GO 165, respectively. Further, deficiencies that cannot be repaired upon discovery are assigned a priority level based upon Electric Operation Manager review. TDPUD will investigate a more formally documented process where deficiencies are assigned to a priority level upon field review. The repairs will be re-defined as Level 1 (highest), Level 2 (moderate), or Level 3 (lowest) as defined by GO 95, Rule 18, with the discovery, remedy, and supporting documentation tracked within TDPUD's GIS. Once this improvement is in place, deficiencies and repairs can be tracked according to priority level. Monitoring the effectiveness of inspection practices will occur through ongoing tracking and annual review of TDPUD's findings, including deficiencies found and corrective actions taken. The Electric Operations Manager or their designee supervises the VMP, all routine fieldwork, and equipment and line inspections. Related strategies that mitigate wildfire risk will be identified and proposed within the next iteration of the Plan. Aggregating these data will guide future decision- making on the direction of the wildfire mitigation strategy with the intention that incidents will become less frequent or less hazardous system wide. F. INDEPENDENT AUDITOR Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 34 Page 98 of 315 Public Utilities Code Section 8387(c) requires TDPUD to contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of this Plan. The independent evaluator must issue a report to be posted on TDPUD's website.This report must also be presented to TDPUD's Board at a public meeting. Navigant Consulting conducted the independent audit of TDPUD's WMP in 2019 and Guidehouse conducted the independent audit in 2023. Both independent audits concluded that: 1. TDPUD's WMP aligns appropriately with Public Utilities Code Section 8387 and includes all required elements. 2. TDPUD's Plan is determined to be comprehensive. TDPUD's WMP satisfied the requirements of Senate Bill 901 and the 2023 WMP considers the previous recommendations of the two audits. It should be noted that TDPUD, in order to maximize the benefit of direct investments in wildfire prevention, only intends to use the independent auditor when there is value, which is currently anticipated to be during comprehensive revisions of the WMP every 3 years or if major changes are made in between. ADOPTION • • Annually, TDPUD presents WMP revisions to the Board for approval before the end of June of each year prior to submitting the WMP to the Wildfire Safety Advisory Board by July 1 st of the same year. Board meetings are typically held on the first Wednesday of the month and the meetings are open to the public except for closed sessions. Members of the public can attend the Board meeting in person. Board meeting agendas included an attached agenda report, such as the one that presents the WMP to the Board, and are available online on the TDPUD website. Board members receive the WMP prior to the meeting date as part of the public Board packet. During the meeting, TDPUD staff presents the WMP to the Board as action item and Board members provide comments when the presentation ends. Board member comments are followed by a period of public comment where the Board opens the meeting for public comment on the WMP. The WMP is either adopted by vote by the Board or returned to TDPUD for revision if there are comments that cannot be resolved during the meeting. The final adoption of the 2022 WMP by the Board was done on June 1, 2022. A similar schedule is anticipated for 2023 adoption. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 35 Page 99 of 315 x REFERENCES Carlson, A.R., D.P. Helmers, T.J. Hawbaker, M.H. Mockrin, and V.C. Radeloff. 2022. "Wildland- urban interface maps for the conterminous U.S. based on 125 million building locations." Retrieved from USGS ScienceBase Catalog: https://www.sciencebase.gov/ catalog/item/617bfb43d34ea58c3c70038f. Town of Truckee Planning Division. 2020. Climate Ready Truckee: A Climate Change Adaptation Plan. Truckee, California: Town of Truckee Planning Division. July 2020. Truckee Donner Public Utility District Wildfire Mitigation Plan Version 4.0 May 22, 2023 36 Page 100 of 315 APPENDIX A CPUC HIGH FIRE THREAT DISTRICT MAP FOR THE TRUCKEE DONNER PUBLIC UTILITY Page 101 of 315 uCl Truckee Donner Public Utility District (TDPUD) Service Territory Fire Threat Areas Vill viva Tier 3 Tier 2 Crystal Bay SOURCE:ESRI World Street Map,CAL Fire 2021 APPENDIX A D U D E K © 0 1 2 Miles CPUC High Fire Threat District Map for the Truckee Donner Public Utility Truckee Donner Public Utility District Wildfire Mitigation Plan Page 102 of 315 APPENDIX B PREVAILING WIND MAP Page 103 of 315 ■ '16 1 ■� ■ ■ ■■ ■ mh 7 � sm ■ °_ ■■ ■ �� AI � ■ ■ ■ ■ im ■ ■� i fi —.a A f ri ■ F- �f f = 1 Truckee Donner Public Utility District e4 (TDPUD) Service Territory Wind Speed (MPH) ,. High : 20.51 MPH A*W� Low : 0.23 MPH EIL 6. - ^�E SOURCE:ESRI Wodd Street Map APPENDIX B D U D E K © o 2 Prevailing Wind Map Miles Truckee Donner Public Utility District Wildfire Mitigation Plan Page 104 of 315 APPENDIX C POLE REPLACEMENT RANKING TOOL Page 105 of 315 Pole Replacement Ranking Tool BACKGROUND In March 2017 District staff initiated a project to prioritize utility pole replacements based on quantitative data. Prior to that, pole replacements associated with Master Plan line upgrades were given priority and other replacements were prioritized by operation staff intuition with limited logical rationale. Staff recognized the importance of prioritizing projects considering Safety, Reliability and Code Compliance. There are approximately 5400 poles maintained by the District. Assuming a service life of 30-50 years approximately 100 to 180 poles should be replaced annually for an asset management/preventative maintenance program. Planning is required to achieve this rate of annual pole replacements and insure engineering,vegetation management, and joint pole planning proceed at a similar rate in advance of the replacement. The Pole Replacement Ranking Tool was developed in response to this need for a project planning and prioritization tool. Originally developed in 2017,the Tool is reviewed and updated periodically. The Tool was most recently updated in February 2020. THE TOOL The Pole Replacement Ranking tool uses GIS feature attributes to assign a score to each pole feature based on the equation: Replacement Score =Age Score+Condition Score +Critical Asset Score This score then becomes an attribute of the pole feature in GIS. The replacement score attribute is then mapped in GIS to provide a visual report of pole replacement priority. The score factors and associated weights are: Age 20% Condition 60% Critical Asset 20% The maximum score for a pole is 100 pts (100%). The weight assigned to each score represents the estimated risk associated with leaving a given pole in service. Age and Condition establish a 'health' score for the pole,while the Critical Asset factor establishes a relative safety and reliability risk of facilities. AGE Poles under 35 years old are considered low risk and are assigned an age score of zero. As poles age the Age score increases as noted below. Age (years) Score 60 or older Oldest 20 55-59 16 50-54 12 3/9/2020 Page 1 Page 106 of 315 P/ole Replacement Ranking Tool 45-49 8 40-44 4 35-39 2 0-34 Newest 0 CONDITION There are two elements to the Condition score: GO165 intrusive inspection results and annual patrol inspection results. The Condition: Intrusive Inspection result is a rating from 1 (best) to 5 (worst) recorded in the GO165 inspection Poles Requiring Replacement reports. Intrusive Inspection Rating Score 1 Best Pole OK 0 2 Decay/Mechanical Damage 8 3 Recommend Change Out 16 4 Reject- Reinforceable 24 5 Worst Priority Pole 32 The Condition: Patrol Inspection result is a rating from 1 (best)to 5 (worst) based on the annual visual inspection of 100%of the poles in the District. Patrol Inspection Rating Score 1 Best recommend future action 5 2 Future action 3 categories 10 3 Intrusive tag+2 categories 15 4 Urgent Action 20 5 Worst Urgent Action +2 categories 28 CRITICAL ASSET The Critical Asset factor ranks facilities based on the impact an event on a given pole could have on Safety, Reliability and Compliance. Attribute ID Asset Score 1 Distribution 20 2 Secondary 15 4 Guy 5 3 Street Light 0 5 Transmission 0 6 Broadband 0 7 Tree 0 While an event on a Transmission pole could have a significant impact on the distribution system,these facilities are not owned by the DISTRICT and are not included in the pole replacement tool. Currently the tool assigns the Tree asset a zero score as trees typically have secondary/service attachments and, if the tree fails,then the impact on the distribution system is limited. With the increased emphasis on wildfire mitigation and the District's stance on tree attachments, this weighting may be reconsidered. The final Replacement Score is mapped in GIS by range. Score Range Color 61-100 Red 3/9/2020 Page 2 Page 107 of 315 P/ole Replacement Ranking Tool 51-60 Orange 41-50 Yellow 31-40 Light Green <=30 Dark Green 2020 REVISION The 2017 version of the tool used the equation: Replacement Score=Age Score+Condition Score+Critical Asset Score+Reliability Score The Reliability score was to be based on outage management system (OMS) data and reflect the frequency of events on a given device. The Reliability score was not included in the 2017 version of the tool while staff evaluated the parameters. Since then, staff determined the OMS data does not correlate to pole health or the safety/reliability risk of leaving a pole in service. As a result,this factor was not included in the 2020 revision. The OMS data is important to safety and reliability and is considered in planning and prioritizing other engineering and operations activities. In the 2020 version of the Tool, staff identified Condition as the most important indicator of health and reallocated scoring accordingly. Less emphasis was given to Age, more emphasis given to Condition and Critical Asset emphasis remained unchanged. Staff also determined annual Patrol Inspection results were available. This data is important and up-to-date information related to pole health and has been added the Condition factor scoring. FUTURE TOOL IMPROVEMENTS Coordinate the patrol inspection data collection tool with the pole ranking tool to more accurately identify, rank/prioritize and record pole health. 3/9/2020 Page 3 Page 108 of 315 APPENDIX D VEGETATION MANAGEMENT PROGRAM Page 109 of 315 00-rTRUCKEE DONNER ublic Utility District Vegetation Management Plan Revised: May 23, 2022 Page 110 of 315 INDEX Section Page Introduction 3 Service Area 3 Plan Description 3 Plan Personnel 5 Plan Operation Elements 5 Clearance Requirements 8 Regulatory Requirements 9 Exhibits 11 2 Page 111 of 315 VEGETATION MANAGEMENT PLAN Truckee Donner Public Utility District Mission Statement — District Code, Title 1, Section 1.05.010 The Mission of Truckee Donner Public Utility District is to provide reliable, high quality utility and customer services while managing the District's resources in a safe, open, responsible, and environmentally sound manner at the lowest practical cost. Introduction The Truckee Donner Public Utility District (the District) has a responsibility to maintain vegetation so as not to threaten the safety and integrity of electric facilities. The District's Vegetation Management Plan (the Plan) is an important part of the District's effort to deliver safe, reliable and cost-effective electric service to customers. The goals of the Vegetation Management Plan include: (1) ensuring the safety of District Personnel and the public, (2) reduction of fire risks due to tree contacts or electrical sparks igniting vegetation (3) the prevention of customer outages due to tree contacts, and (4) aesthetics. The Plan is designed to meet the goals and objectives of the District, as well as State and Federal requirements, as they relate to maintenance of electric facilities in Public Utility Easements (PUE). Service Area The District is a Public Utility District of the State of California engaged in the distribution, sale and delivery of electric power and energy. The District is a transmission-dependent utility connected to NV Energy's transmission system and is located high on the eastern slope of the Sierra Nevada. The District is not interconnected with any other utility. The District's electric service territory is comprised of approximately 44 square miles in eastern Nevada County and approximately 1.5 square miles in adjacent Placer County. The electric system includes approximately 135 miles of 12.47 kV and 14.4 kV overhead distribution lines, and about one-half mile of 60kV overhead transmission lines. The District has approximately 5,490 poles in its service territory, making the tree trimming budget one of the largest annual operational expenses for the District. Plan Description The District is required by State and Federal laws and regulations to prune or remove vegetation close to energized electrical facilites for public safety and electric system reliability. The District adheres to all applicable vegetation clearance requirements and performs regular vegetation managment in accordance with State and Federal requirements, industry standards, and other procedures that help to prevent outages and fires due to tree contact. District staff are responsible for preparing work plans for annual vegetation management operations. In addition, staff routinely performs quality control (QC) audits for ongoing work for adherance to clearance requirements and to track progress throughout the year. Circuits are 3 Page 112 of 315 patrolled and maintained on an ongoing basis, enabling the District to cover all overhead electiric lines on a rotating five-year cycle. While conducting routine vegetation management operations, the District removes any identified high-risk fuel source vegetation, as required. The District also performs inspections of vegetation concerns for customers or when vegetation management contractors identify at-risk vegetation while performing day-to-day operations. Staff is constently evaluating methods to improve and enhance inspection procedures and vegetation operations. Vegetation management generally consists of removing, cutting, trimming, and clearing away of trees, tree limbs, branches, bushes, vines, foliage, the removal of hazard trees, and inspection of legacy tree attachments in proximity to electrical lines, substations, and other District property within the PUE. Vegetation removal is performed by mechanical trimming in and around transmission and distribution circuits, from the substations to the end of the each feeder circuit. An emphasis is placed on the removal of tree branches and trees that are located within clearance limits, ground- level clearing around poles, vegetation clearance within the PUE, plus the removal of hazard trees that may be located inside or outside of the PUE. The District does not perform vegetation removal operations in the following areas: 1. Supply Service Drops Supply service drops, or service wires, are defined as the overhead conductor from the District's distribution pole line to the customers' service entrance or meter base equipment. These overhead supply lines are generally energized at 240 volts. The District does not perform vegetation management operaions along customer supply service drops. Tree triming and maintaining the health of trees on private property is the customer's or property owner's responsibility. The customer or property owner shall maintain a 4 foot clearance at time of trim and a minimum 2 foot clearance from supply service drops to trees and other vegetation at all times. Upon request, and during normal business hours, the District will temporarily de-energize or remove the customer's overhead secondary service line at no charge to the customer, thereby allowing for tree trimming or maintenance work to be performed safely. 2. Padmounted Equipment In areas served by underground electric facilities, padmounted equipment, including transformers and switchgear, are placed at customer locations or select intervals along main electric lines near streets and roads. Per District code, employees must be able to access this equipment at any time for routine maintenance, troubleshooting, or emergency repairs. This equipment must be visually and phyisically accessable to District crews at all times. A clear working area must be maintained on all sides of padmounted equipment. The door side shall have a 10 foor minimum clear working area. The non-door sides shall have 3 foot minimum clear working area. Clear working area shall mean no fences, shrubs, trees, landscape rocks or other obstructions. The customer or property owner shall maintain these clear working areas for District access. 4 Page 113 of 315 Plan Personnel District crews consisting of licensed Journeymen Linemen perform tree trimming operations on an as-needed basis. The majority of the Plan work is performed by licensed tree contractors specializing in vegetation management operations for electric utiltities. Contracts for Vegetation Management are signed for one year, with up to three, one year extensions.The District has very strict requirements for selecting a tree contractor following the public procurement process. The contractor's field supervisor must be a certified arborist with the International Society of Arboriculture. The Contractor must employ only qualified line clearance tree trimming personnel meeting the requirements of OSHA 29 CFR 1910.269, ANSI Standard Z133.1, and California Code of Regulation Title 8 Article 38 standards and requirements. In addition, the contractor must have a category D-49 Tree Service Contractor license issued by the California Contractors State License Board and be a State of California issued Licensed Timber Operator (LTO). Plan Operation Elements 1. General Vegetation management operations are performed by mechanical trimming or removal of trees and other vegetation along distribution and transmission line circuits. These operations are performed in a manner which creates minimum disturbance to the surrounding natural vegetation and landscape not directly involved in the work. Ingress and egress to work areas are via existing roads, driveways, access roads, etc. The work is performed so as to cause the least possible obstruction and inconvenience to public traffic. Public vehicular and pedestrian traffic is allowed to travel through the work area with a minimum of interruption or impedance unless otherwise required for safety concerns. All traffic control and related devices conform to requirements set forth by the Town of Truckee. 2. Scheduled Maintaince Cycle Trees and vegetation are cleared from District facilities on a scheduled maintenance cycle. The District's maintenance cycle goal is 5 years for all facilites. This means that trimming operations are performed on the same portion of a distribution or transmission line typically once every 5 years. The intent of the scheduled maintenance cycle is to perform trimming necessary to obtain clearance that will last for the duration of the cycle. Other benefits include improved access to electric facilities and reduced future maintenance costs. Facilities are worked in a systematic approach. Operations are recorded by staff on the District's Geographical Information Systems (GIS) mapping database to track maintenance cycle goals. 3. Public Utility Easement (PUE) Clearing The District has the right of access to PUEs and other dedicated electric service easements for purposes related to vegetation management including pole clearing, tree trimming, tree removal, and easement clearing. In the event a recorded easement does not exist, easements by prescription, also called prescriptive easements under California Law, give the District the same rights as recorded easements for access to District facilities. Any tree regardless of size, that's 5 Page 114 of 315 located in the PUE may be removed due to present or future conflicts with electrical facilities as determined by District staff. PUE maintenance includes pole clearing, cutting and trimming of all trees and shrubs to the extent necessary to keep electric facilities clear of vegetation and to provide access for electric system operations and maintenance. Refer to Exhibits for a graphical depiction of clearance requirements and PUE clearing activities. 4. Notification of Customers and/or Property Owners Customers and/or property owners are notified a minimum of twenty-four hours prior to any scheduled vegetation management operations adjacent to private property. The notificaion includes the type of work to be performed, including the trimming or removal of trees and the disposal of logs and/or brush. This is typically done by placing "door hangers" or using other communication methods to notify customers of impending work. The work may also require temporary power interuptions or planned outages to be performed safely. This work shall be reviewed and authorized by the Electric Operations Manager or their designee prior to the commencment of work. The customer notification contains information such as contractor name, address, contact name, phone number, approximate time and duration of planned outage, and District contact information. 5. Types of Trimming Natural pruning techniques are performed as recommended by the International Society of Arboriculture and ANSI Standard A300. Operations avoid practices that can cause damage or injury to the tree while achieving the required clearance objectives. Wherever possible, natural pruning cuts are made to direct future growth and sprouting away from electric facilities. a. Pruning: Tree pruning is performed so as to maintain the minimum clearance requirements from electric conductors as shown in the Clearances section of this document. Dead branches overhanging conductors are removed. Portions of dead or decaying trees or portions of trees weakened by decay or disease that may contact conductors from the side or by falling are pruned to eliminate the hazard. b. Crown Reduction: Trees directly under conductors are pruned and shaped. The tree crown is typically reduced and rounded into a symmetrical appearance as much as possible. Conifers are pruned in a natural manner that allows them to retain as much of their natural shape as possible. c. Side Prunes: Where line clearance tree pruning adversely alters the shape of a tree, additional pruning is performed to give such trees a better shape and appearance. 6. Tree Removal Tree removal is performed for all trees that do not meet the clearance requirement from the tree trunk to energized conductors and also for hazard trees. Hazard trees are trees with the potential to fail and threaten the reliability of the District's overhead electric facilities. Hazard trees may be 6 Page 115 of 315 located inside or outside of the PUE. The District will notify and obtain approval from property owners when tree removal work is outside of the PUE. Hazard trees are defined as any tree or portion of a tree that is dead, split, rotten, decayed or diseased and which may fall into or onto electric facilities or trees leaning towards lines. Tree removal includes the falling of the entire tree or crane removal. It also consists of the removal and disposal of trunks, limbs and branches. Following best forest management practices, trees are cut off at ground level to leave a stump height of no more then 3 inches to promote natural decay. The District is not responsible for the removal of stumps. 7. Pole Clearing The pole clearing program is an annual requirement to clear vegetation around poles that contain electric apparatus in addition to wires in compliance with California Public Resources Code Section 4292. This Code applies to a majority of District poles. The District will notify and obtain approval from property owners when vegetation removal work is outside of the PUE. In addition, ground level vegetation clearance and removal is performed to provide the required firebreaks and to minimize new spring growth which are essential steps in reducing impacts to the electrical distribution system due to wildland fires. Refer to Exhibits for a graphical depiction of clearance requirements and PUE clearing activities. 8. Tree Attachments (Legacy Attachments) The District has legacy attachments to trees that consist of: service drop(s); secondary conductor(s); or, security lighting. Although these installations are permitted pursuant to California Code 14CCR § 1257, the District does not engage in this practice for new installations. In order to ensure the integrity of these attachments, the District performs the following: • Inspect legacy tree attachments and correct any hazardous condition found such as tree growth around conductors, physical signs of damage, etc; • Remove tree limbs on trees used as an attachment point(s) consistent with 14CCR § 1257; • Accurately record attachment point(s) on GIS mapping database for audit purposes. 9. Control of Material and Clean Up Tree branches and other vegetation less than 5 inches in diameter are chipped and removed from the work area. Wood larger than 5 inches in diameter is cut into lengths for safe lifting purposes. Wood larger than 5 inches in diameter is made available to District customers before removal by the contractor. Customers on whose property a tree or trees have been removed or who are adjacent to such work will have the first opportunity to use the wood collected from such trees before removal by the contractor. The work is performed in an environmentally responsible manner with regards to any and all material generated by the work. 7 Page 116 of 315 The District may store timber logs temporaraly at the work site while efforts are made to arrange for removal and transport to the mill or final storage facility. Upon completion of the work, the area is cleaned to a condition at least equal to that which existed prior to the commencement of the work. During winter storm restorations, these logs may be left for an extended period of time due to heavy snow fall making them inaccesable to load after power restoration efforts are complete. In these situations the District or its contractors will do their best to minimize impacts to customers by stacking material off of the roadyway or other accessible public walkways. Clearance Requirements The following table reflects the District's current minimum clearances required between conductors and vegetation: Clearance of Conductors to Vegetation Trimmed Minimum Type of Clearance Clearance Conductor Voltage Secondary 0 to 750v 4 ft. 2 ft. Supply Conductors Primary 750v to 12 ft. (1, 3) 4 ft. (2,3,4&5) Supply 22,500v Conductors Primary 22.5kV to 12 ft. (1, 3) 4 ft. (2,3& 4) Supply 72.5kV Conductors Notes: 1. GO 95 Appendix E, Guidelines to Rule 35, Case 14, High Fire Threats 2. GO 95 Rule 35, Vegetation Management; Table 1, Case 14, High Fire Threats 3. CPUC Fire Threat Map: The CPUC has identified the District's service territory as a Tier 2 High Fire Threat District (HFTD), with the Tahoe Donner Subdivision identified as a Tier 3, HFTD. Therefore, greater clearance requirements apply as compared to being in a non- fire threat area. 4. California PRC Section 4293 5. The minimum clearance may be reduced to 6 inches for tree trunks and major limbs "of sufficient strength and rigidity to prevent the trunk or limb from encroaching upon the 6 inch minimum clearance under reasonable foreseeable wind and weather conditions'; GO 95 Rule 35, Tree Trimming, Exception No. 4. s Page 117 of 315 Regulatory Requirements The District performs vegetation managment in accordance with State and Federal requirements. In addition, the District follows industry standards, and other procedures that help to prevent outages and fires due to tree contact. These requirements, standards, and procedures include: • California General Order No. 95, Rule 35 —Vegetation Management This rule specifies the minimum radial clearance that must be maintained at all times from energized conductors to vegetation. • California General Order No. 95, Appendix E — Guidelines to Rule 35 This rule specifies the minimum radial clearance that must be maintained from energized conductors to vegetation at time of trimming. • California General Order No. 95, Rule 21.2 D — High Fire Threat District This rule specifies the use of California Public Utility Commission (CPUC) Fire Threat Map to identify fire threat level zones. • California General Order No. 95 Rule 35, Vegetation Management; Table 1, Case 13, Radial Clearance requirments Radial clearance of bare line conductors from tree branches or foliage. • California General Order No. 95 Rule 35, Vegetation Management; Table 1, Case 14, High Fire Threats Radial clearance of bare line conductors from vegetation in Extreme and Very High Fire Threat Zones. • California Public Utility Commission (CPUC) Fire Threat Map This is the CPUC's statewide Fire Threat Map identifing areas of the state at an elevated (Tier 2) or extreme (Tier 3) risk of power line ignitied wildfire. • California Public Resources Code Section 4292 This law is administered by the California Department of Forestry and Fire Protection (CALFIRE). The law requires the maintenance of a 10 foot radial firebreak around electric utility poles that contain switches, fuses, transformers, or other electric equipment. • California Public Resources Code Section 4293 This law is administered by CALFIRE. The law specifies the minimum clearance between energized conductors and vegetation. It also requires the removal of dead, deseased, or dying trees, or trees that could fall into electric lines. Such trees may be located inside or outside of the right-of-way or easement areas. • California Administrative Code, Title 8, Article 37 - Proximity to Overhead Lines This code specifies minimum clearances between personnel and equipment working in close proximity to overhear electric facilities. 9 Page 118 of 315 • California Administrative Code, Title 8, Article 38 - Line Clearance Tree Trimming Operations This code specifies requirements for personnel performing line clearance tree trimming operations. • California General Order No. 165 — Inspection Requirements for Electric Distribution and Transmission Facilities This rule specifies the minimum cycle times for inspection of electric distribution and transmission lines. • ANSI A300.1 — Tree Care Operations - Pruning This national standard addresses pruning practices for tree trimming operations. • ANSI Z133 - Standard for Safety Requirements in Arboricultural Operations This national standard addresses arboriculture safety requirements for pruning, repairing, maintaining and removing trees, and for using equipment in such operations. • OSHA 29 CFR 1910.269 - Electric Power Generation, Transmission, and Distribution This federal standard specifies requirements for worker safety in the electric power industry. • ISA Best Management Practices — Vegetation Managment The International Society of Arboriculture (ISA) developed this BMP for the selection and application of methods and techniques for vegetation control for electric rights-of-way. • District and other standards as referenced in this document. 10 Page 119 of 315 Exhibits Vegetation Management Handouts Truckee Donner 1Vegetation • Program Helping • Keep Our Community SAFE!(See reverse to learn more) Required Clearances to Vegetation California Public Utilities for High Fire Threat Areas ..................................... Com mission General Order 95, Rule 35,requires 12-foot minimum radVegetation Removal Requirements coed corsattimnce oftrim.energized / / conductors at time of trim. TDPUD is required by state law and regulations 12 12 General Order 95 also requires a to remove vegetation close to power lines for 4-foot minimum radial clearance to public safety and reliability.This consists of any vegetation at all times. tree trimming*and tree removal**. TDPUD will notify occupants in advance of t 4/ 4/ routine tree trimming work. i •, i ..... �•••.. .... *Tree trimming .. . 20/ required Public Utility Easement(PUE) Hazard Tree Removal** i TDPUD is required to remove any dead,diseased, or dying trees,located inside or outside of PUEs, that have the potential to fall on utility lines. • •' i TDPUD will notify and obtain approval from ' • i 11�1 property owners when tree removal work is •. • i /, outside the PUE. OF .*Tree,shrub,and vegetation removal required TRUCKEE DONNER PUBLIC UTILITY DISTRICT 530.587.3896 tdpud.org/wildfire-safety Followus!Jf 11 Page 120 of 315 ARE YOU PREPARED FOR &"&10VU SEASON? Ongoing Vegetation Management Work Truckee Donner PUD's dedicated staff and contractors are busy Conducting vegetation management including,tree trimming and removal of hazard trees around power lines,and maintaining defensible space on properties owned by TDPUD. Please do your part to protect your home or business and our community.Visit tdpud.org/wildfire-safety for information and links to resources. e Sign up for emergency alerts and notifications Does TDPUD have your updated customer contact information? Do you want to be notified during wildfire safety outages(PSOM) and emergency situations?TDPUD customers can customize email and text notifications,as well as push alerts by visiting tdpud.org I WRIGHT r and clicking on the My Account button. TDPUD has partnered with Nixle to provide targeted alerts to TDPUD customers,community members,and the public Everyone can sign up for TDPUD Nixle emergency alerts by texting TDPUD to 333111. Are you prepared for power outages? Tak TDPUD has taken steps to make our electrical system more safe �1�e+ e11 during wildfire season,but the result is more and longer outages. y t'�. d O Go to tdpud.org/wiIdfire-safety to learn more. a7 3 n A t. --EPAa 12 Page 121 of 315 ATTACHMENT 2 Guidehouse Outwit Complexity Independent Evaluation of Truckee Donner Public Utility District's 2023 Wildfire Mitigation Plan Prepared for: Truckee Donner Public Utility District TRUCKEE DONNER Public Submitted by: Guidehouse Inc. 4001 South 700 East Salt Lake City, LIT 84107 May 25, 2023 guidehouse.com This deliverable was prepared by Guidehouse Inc.for the sole use and benefit of,and pursuant to a client relationship exclusively with Truckee Donner Public Utility District("Client").The work presented in this deliverable represents Guidehouse's professional judgement based on the information available at the time this report was prepared.Guidehouse is not responsible for a third party's use of,or reliance upon,the deliverable, nor any decisions based on the report. Readers of the report are advised that they assume all liabilities incurred by them,or third parties,as a result of their reliance on the report,or the data, information,findings and opinions contained in the report. Page 122 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan Table of Contents ExecutiveSummary...................................................................................................... 1 1. Background ...............................................................................................................2 1.1 Wildfire Mitigation Plans .............................................................................................. 2 1.1.1 SB 901 ..............................................................................................................2 1.1.2 AB 1054 Statutory Modifications.......................................................................3 1.2 Truckee Donner Public Utility District Plan Preparation ............................................... 3 Independent Evaluation Services...............................................................................3 2. Evaluation Scope and Approach ............................................................................. 5 2.1 Evaluation Parameters................................................................................................ 5 2.1.1 WMP Requirements..........................................................................................5 2.1.2 Industry Knowledge and Regulatory Proceedings.............................................6 2.2 Evaluation Approach ................................................................................................... 6 2.2.1 Statutory Compliance........................................................................................7 2.2.2 Industry Wildfire Mitigation Practices Comparison ............................................7 3. TDPUD WMP Elements .............................................................................................8 3.1 Responsibilities of Persons Responsible for Executing the Plan.................................. 8 3.2 Objectives of the Plan ................................................................................................. 8 3.3 Wildfire Prevention Strategies ..................................................................................... 8 3.4 Metrics ...................................................................................................................... 10 3.5 Disabling Reclosers................................................................................................... 10 3.6 De-Energizing Protocols............................................................................................ 10 3.7 Event Communication ............................................................................................... 11 3.8 Vegetation Management ........................................................................................... 11 3.9 Infrastructure Inspections .......................................................................................... 11 3.10 Risk Assessment and Drivers.................................................................................. 12 3.11 Asset Overview and Service Territory...................................................................... 13 3.12 Restoration.............................................................................................................. 16 3.13 Monitoring and Auditing the Plan............................................................................. 17 3.14 Annual Review ........................................................................................................ 17 4. Fire Industry Practices Comparison...................................................................... 18 4.1 Best Practice Comparison......................................................................................... 18 5. Results and Discussion.......................................................................................... 32 Appendix A. Statutory Compliance Matrix.............................................................. A-1 Page i Page 123 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan List of Tables Table2-1 — POU Requirements................................................................................................ 5 Table 3-1 —Truckee Donner Context Setting Table ................................................................ 13 Table 4-1 — Industry Practice Strategy Comparison Matrix...................................................... 19 List of Figures Figure1-1 — Fire Triangle.......................................................................................................... 2 Figure 2-1 — Mitigation Strategy Overview................................................................................. 7 Figure 3-1 — Service Territory Map.......................................................................................... 16 Figure 4-1 — Determinations for Benchmarking ....................................................................... 18 Page ii Page 124 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan Executive Summary Truckee Donner Public Utility District (TDPUD) contracted with Guidehouse Inc. (Guidehouse) to engage in an independent evaluation of its Wildfire Mitigation Plan (Plan or WMP). This independent evaluation report (Report) describes the technical review and evaluation provided by Guidehouse. Guidehouse performed this evaluation in May of 2023 and finalized the Report on May 25, 2023. Guidehouse's project team reviewed detailed information related to the Plan and assessed TDPUD's procedures related to the Plan. The Plan was prepared as a response to Senate Bill (SB) 901. SB 901 included a number of provisions and directives, among which includes the requirement for electric utilities to prepare and adopt WMPs and revise and update the Plan annually thereafter. These requirements are codified in the California Public Utilities Code (PUC) Section 8387 for publicly owned utilities (POUs). Guidehouse evaluated the Plan based on the statutory requirements of PUC Section 8387 as it relates to POUs. This PUC Section was amended in 2019 with the signing of California's Assembly Bill (AB) 1054 into law. The POUs are now subject to the guidance provided by the California Wildfire Safety Advisory Board and mandatory cyclical reviews, including a comprehensive update every three years. The required elements for a WMP have not been modified by this new legislation. This Report is consistent with the requirements under PUC Section 8387(c), regarding an independent evaluation of TDPUD's WMP. The Report was also developed to satisfy the statutory requirement for public review. This Report underlies the required presentation at a public meeting of the TDPUD Board on June 7, 2023, for approval. The Report includes the following: • Background of the legislative history requiring WMPs and their independent evaluations • Approach and methodology evaluating the WMP's comprehensiveness • TDPUD's WMP elements and their compliance with SB 901 and PUC Section 8387 WMP elements and directives • An evaluation of the WMP's presented metrics to assess the effectiveness of the overall WMP • Determinations and results Based on relevant experience in grid hardening and resiliency, natural disaster response, prior experience in WMP development, and active tracking of wildfire legislative and regulatory proceedings Guidehouse has concluded that TDPUD's WMP is comprehensive in accordance with PUC section 8387. Page 1 Page 125 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan 1 . Background In recent years, California has seen numerous utility equipment-involved, catastrophic wildfires. The unique geographic profile of California and the impacts of climate change, including prolonged drought, high winds, and elevated temperatures, have led to elongated fire seasons. The state also has historically high levels of past fire suppression efforts. This increasingly abundant dry vegetation is the leading driver of wildfires. These fuel-rich environments, coupled with intensified climatological conditions with high wind gusts and inherent electrical infrastructure risks, produce the conditions conducive to potential wildfire ignition. The three attributes that provide optimal conditions for a fire ignition are illustrated through the graphic in Figure 1-1. Oxygen Hetr t Fuel Figure 1-1 — Fire Triangle Disastrous wildfire threat is a well-known and shared priority among electric utilities in California. Disastrous utility-involved wildfire incidents and the significant financial and livelihood impacts associated with them led California legislators and regulators to formalize requirements to ensure safe operations of electric utility equipment and greater investment in wildfire mitigation efforts. Specifically, the state has approved legislation that strengthens governmental and regulatory oversight of wildfire prevention implementation activities, utility wildfire mitigation plans, and proper dispersal of state funds to wildfire victims. In an effort to minimize future devastating occurrences through risk-driven wildfire prevention, electric utilities, including cooperatives, were mandated, by SB 901 (Senator Bill Dodd, 2018), to prepare and annually adopt a wildfire mitigation plan. This effort is foundational to the state's prioritized goal of minimizing the potential of devastating fires in future years. 1.1 Wildfire Mitigation Plans 1.1.1 SB 901 In an effort to minimize future devastating occurrences through risk-driven wildfire prevention, electric utilities, including publicly owned utilities (POUs), were mandated, by Senate Bill (SB) 901 to prepare and annually adopt a WMP. The WMPs must Include several mitigation and response elements in each utility's strategies, protocols, and programs. The requirements for POUs are codified in Public Utilities Code (PUC) Section 8387. Details relating to POU requirements are discussed in Section 2 of this WMP evaluation report (Report). Page 2 Page 126 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan 1.1.2 AB 1054 Statutory Modifications In 2019, Assembly Bill (AB) 1054 was signed into law, modifying the requirements for POU WMPs. AB 1054 aims to mitigate the intensity of wildfire impacts through several initiatives separate from those actions required of electric utilities. AB 1054 includes directives to establish the Wildfire Safety Division' at the California Public Utilities Commission and the state's Wildfire Safety Advisory Board (WSAB). AB 1054 requires POUs submit their WMPs by July 1 of each year for review by and recommendations from WSAB and requires POUs to comprehensively update their WMPs at least every three years. The most recent Guidance Advisory Opinion for 2022 POU WMPs was published on March 2, 2022. 1.2 Truckee Donner Public Utility District Plan Preparation The Truckee Donner Public Utility District (TDPUD) is a special district of the State of California engaged in the distribution, sale, and delivery of electric power and water. TDPUD provides retail electric service to about 14,648 customers as of December 31, 2022. TDPUD is a transmission-dependent utility connected to NV Energy's transmission system and is located high on the eastern slope of the Sierra Nevada. TDPUD is not directly interconnected with the California transmission system nor to any California utility in a meaningful way. TDPUD's electric service territory comprises approximately 44 square miles in eastern Nevada County and approximately 1.5 square miles in adjacent Placer County. The electric system includes approximately 225 miles total with 135 miles of 12.47 kilovolt (kV) and 14.4 kV overhead distribution lines, and about 0.5 miles of 60 kV overhead transmission lines. In total, TDPUD has 5,490 poles in its service territory. The TDPUD Wildfire Mitigation Plan (WMP or Plan) is adopted by the TDPUD Board (the Board) during a public meeting. TDPUD staff present the final version of the annual WMP to the Board for review. Included with the Plan is an agenda packet with a summary of the background and the contents of the current WMP. The agenda packet also includes a description of major changes from the previous year's WMP. This WMP describes the range of activities and strategies TDPUD is taking to mitigate the threat of overhead power line- and equipment-ignited wildfires, including its various programs, policies, and procedures. It addresses the unique features of TDPUD's service area such as topography, weather, infrastructure, grid configuration, and potential wildfire risks. This Plan is subject to direct approval by TDPUD's Board of Directors and is implemented by the General Manager. This Plan is prepared and maintained in accordance with Public Utilities Code Section 8387 for publicly owned electric utilities to prepare a WMP by January 1, 2020, and to evaluate and update annually thereafter. Independent Evaluation Services PUC Section 8387(c) directs POUs to procure an independent evaluation (IE) of the comprehensiveness of the WMP which TDPUD completed with the first WMP in 2019. The provisions of PUC Section 8387 state that the "qualified independent evaluator" shall be ' Oversight and responsibility for the Wildfire Safety Division was transferred from the California Public Utilities Commission to the California Natural Resources Agency on July 1, 2021 and is now known as the Office of Energy Infrastructure Safety. Page 3 Page 127 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan experienced in "assessing the safe operation of electrical infrastructure" and will perform an assessment to determine the comprehensiveness of the WMP. TDPUD sought IE services to assess the comprehensiveness of its WMP consistent with PUC Section 8387(c). TDPUD selected Guidehouse to perform this assessment based on Guidehouse's prior experience with assessing the safe operation of electrical infrastructure, including grid-hardening and WMPs, with an emphasis on electrical equipment, public, and personnel safety. Guidehouse has conducted over 12 independent evaluations of POUs across California and is a California Office of Energy Infrastructure Safety ("Energy Safety") designated qualified independent evaluator for the last two years, and as such has conducted six independent evaluations of three CA IOUs. This Report presents the results of Guidehouse's WMP IE. Page 4 Page 128 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit complexity Wildfire Mitigation Plan 2. Evaluation Scope and Approach Guidehouse completed this evaluation based on industry standard practices, our experience performing independent evaluations of WMPs, our active tracking of wildfire regulatory proceedings, WSAB guidance, and, most importantly, a comparison of the specific criteria in PUC Section 8387(b)(2) to the specific wildfire-related plans outlined in TDPUD's WMP. 2.1 Evaluation Parameters 2.1.1 WMP Requirements Table 2-1 lists the requirements for the statutory requirements for POUs to address in their WMPs. Table 2-1 — POU Requirements PUC Section 8387 (a) Each local publicly owned electric utility and electrical cooperative shall construct, maintain,and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment. (b)(1)The local publicly owned electric utility or electrical cooperative shall, before January 1,2020, prepare a wildfire mitigation plan.After January 1,2020, a local publicly owned electric utility or electrical cooperative shall prepare a wildfire mitigation plan annually and shall submit the plan to the California Wildfire Safety Advisory I Board on or before July 1 of that calendar year. Each local publicly owned electric utility and electrical cooperative shall update its plan annually and submit the update to the California Wildfire Safety Advisory Board by July 1 of each year.At least once every three years,the submission shall be a comprehensive revision of the plan. F i (2)The wildfire mitigation plan shall consider as necessary, at minimum,all of the following: Y Y (A)An accounting of the responsibilities of persons responsible for executing the plan. ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- (B)The objectives of the wildfire mitigation plan. ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- (C)A description of the preventive strategies and programs to be adopted by the local publicly owned electric utility or electrical cooperative to minimize the risk of its electrical lines and equipment causing catastrophic wildfires, including consideration of dynamic climate change risks. --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- (D)A description of the metrics the local publicly owned electric utility or electrical cooperative plans to use to I evaluate the wildfire mitigation plan's performance and the assumptions that underlie the use of those metrics. --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- (E)A discussion of how the application of previously identified metrics to previous wildfire mitigation plan performances has informed the wildfire mitigation plan. (F) Protocols for disabling reclosers and deenergizing portions of the electrical distribution system that consider the associated impacts on public safety, as well as protocols related to mitigating the public safety impacts of those protocols, including impacts on critical first responders and on health and communication infrastructure. ------------------------------------------------------------------------------------------------------------------------------------------------ (G)Appropriate and feasible procedures for notifying a customer who may be impacted by the deenergizing of electrical lines.The procedures shall consider the need to notify, as a priority,critical first responders, health care facilities, and operators of telecommunications infrastructure. (H) Plans for vegetation management. ------------------------------------------------------------------------------------------------------------------------------------------------ (1) Plans for inspections of the local publicly owned electric utility's or electrical cooperative's electrical infrastructure. Page 5 Page 129 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan A list that identifies, describes, and prioritizes all wildfire risks, and drivers for those risks, throughout the local publicly owned electric utility's or electrical cooperative's service territory.The list shall include, but not be limited to, both of the following: --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Risks and risk drivers associated with design,construction, operation, and maintenance of the local publicly owned electric utility's or electrical cooperative's equipment and facilities. F a Particular risks and risk drivers associated with topographic and climatological risk factors throughout the different parts of the local publicly owned electric utility's or electrical cooperative's service territory. ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Identification of any geographic area in the local publicly owned electric utility's or electrical cooperative's service territory that is a higher wildfire threat than is identified in a commission fire threat map, and identification of where the commission should expand a high fire-threat district based on new information or changes to the environment. ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- A methodology for identifying and presenting enterprise wide safety risk and wildfire-related risk. ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- A statement of how the local publicly owned electric utility or electrical cooperative will restore service after a wildfire. Y i A description of the processes and procedures the local publicly owned electric utility or electrical cooperative shall use to do all of the following: F i Monitor and audit the implementation of the wildfire mitigation plan. F i Identify any deficiencies in the wildfire mitigation plan or its implementation,and correct those deficiencies. r--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- Monitor and audit the effectiveness of electrical line and equipment inspections, including inspections performed by contractors,that are carried out under the plan,other applicable statutes,or commission rules. Y i (3)The local publicly owned electric utility or electrical cooperative shall, on or before January 1, 2020, and not less than annually thereafter, present its wildfire mitigation plan in an appropriately noticed public meeting.The local publicly owned electric utility or electrical cooperative shall accept comments on its wildfire mitigation plan from the public, other local and state agencies, and interested parties, and shall verify that the wildfire mitigation plan complies with all applicable rules, regulations, and standards,as appropriate. ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- (c)The local publicly owned electric utility or electrical cooperative shall contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness of its wildfire mitigation plan.The independent evaluator shall issue a report that shall be made available on the internet website of the local publicly owned electric utility or electrical cooperative, and shall present the report at a public meeting of the local publicly owned electric utility's or electrical cooperative's governing board. ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- 2.1.2 Industry Knowledge and Regulatory Proceedings The state's priority towards abating future catastrophic wildfire events is demonstrated through aggressive measures, directing utilities to enhance their protocols for fire prevention, public communications, and response. That collection of information is presented in a comprehensive WMP. Guidehouse tracks state proceedings and routinely advises, assesses, and guides utility wildfire mitigation efforts. Accordingly, we reviewed TDPUD's WMP against the provisions in PUC § 8387 and relative to its risk profile which includes, but is not limited to, its topography, climate, assets, and structure. 2.2 Evaluation Approach Guidehouse assessed the comprehensiveness of the plan against the applicable regulations to determine whether TDPUD meets the standard set forth in PUC § 8387(c). Page 6 Page 130 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan 2.2.1 Statutory Compliance Guidehouse sought to determine compliance with the provisional requirements laid out in SB901 as codified in PUC Section 8387. The WMP's alignment with the statutory requirement is presented in Appendix A. TDPUD's mitigation measures are not required to exceed the statutory requirements. 2.2.2 Industry Wildfire Mitigation Practices Comparison Guidehouse's understanding of an effective WMP draws on comparisons from existing WMPs and industry practices, WSAB guidance, risk profile, and mitigation strategy. This mitigation strategy analysis is visually summarized in Figure 2-1. Situational Et 1- .- • O•- • pone . Conditional Construction Maintenance Practices Recovery Awareness Ueslan&Construction: Inspection&Maintenance: Operational Practices: Awareness: Response&Recovery: System,equipment,and Assessment and diagnostic Proactive,day-to-day Methods to improve Procedures to react to de- structure design and activities as well as actions taken to mitigate system visualization and energizatiun,wildfire,or technical upgrades associated corrective wildfire risks aimed to awareness of other related emergency designed to improve actions aimed to ensure all ensure the POU is prepared environmental conditions conditions,aimed to system hardening to infrastructure is in working in high-risk situations,such aimed to provide tools to formalize protocols for prevent contact between condition and vegetation as dry,windy improve the other these situations,so the infrastructure and fuel adheres to defined environmental conditions. components of the plan. POU can provide an sources,such as minimum distance adequate response and vegetation. specifications. recovery. Figure 2-1 - Mitigation Strategy Overview These critical elements are evaluated as part of Guidehouse's review of the comprehensiveness of TDPUD's WMP. This evaluation includes a consideration that not all of these strategies are necessarily present in or applicable to TDPUD's WMP, due to TDPUD's inherent risk, size, location, and operational characteristics. Page 7 Page 131 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan 3. TDPUD WMP Elements Guidehouse reviewed the WMP elements to determine whether the activities achieve the objective of WMP "comprehensiveness" of PUC Section 8387. This determination incorporates individual elements as well as underlying data sources that further describe data collection methodologies and implementation procedures to ensure measures are carried out and tracked. In this section, we review the WMP's elements and their purpose relative to the development and successful execution of the WMP. A table comparing each subsection of PUC Section 8387 to the significant sections of the WMP can be found in Appendix A. 3.1 Responsibilities of Persons Responsible for Executing the Plane TDPUD utilizes a special district Board/General Manager reporting hierarchy. The Board is responsible for the adoption and oversight of all policies and delegates the operational implementation of policies to the General Manager. The General Manager has full operational authority of TDPUD. The General Manager operates as the chief executive and provides direction and management to all TDPUD staff. In addition to the General Manager TDPUD has an Electric Utility Director/Assistant General Manager, a Public Information Officer/Strategic Affairs Director, an Electrical Operations Manager, and an Electric Engineering Manager. The Public Information Officer/Strategic Affairs Director serves as the liaison to customers and outside agencies. The Electrical Utility Director/Assistant General Manager has overall functional management of the electric utility and provides day-to-day oversight of the electric utility. The Electric Operations Manager oversees the daily electric utility operations, including construction, maintenance, energy control, fleet, vegetation management, and other ancillary daily duties. Finally, the Electrical Engineering Manager oversees the design/engineering tasks associated with distribution system modifications and development/maintenance of material specifications. This level of assignment is appropriate for a utility the size of TDPUD. 3.2 Objectives of the Plana The objectives of TDPUD's WMP are described in Section II and include: • Minimizing Sources of Ignition — Primary • Resiliency of the Electrical Grid — Secondary • Minimizing Unnecessary or Ineffective Actions — Tertiary TDPUD provides more detail to each of these objectives in the subsections within Section 2 associated with each objective. 3.3 Wildfire Prevention Strategies' Section V provides an overview of TDPUD's preventative strategies and programs for preventing wildfire. These programs include, weather monitoring, design and construction 2 PUC Section 8387(2)(A) 3 PUC Section 8387(2)(B) 4 PUC Section 8387(2)(C) Page 8 Page 132 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan standards, vegetation management, inspections, workforce training, recloser policy, and de- energization. Section V.C, Design and Construction Standards, addresses of all the system hardening programs that TDPUD is currently undergoing to reduce the risk of utility ignited wildfire in its service territory. These programs include: • Pole Replacement—An ongoing program that prioritizes poles for replacement based on three factors of inspection (age, condition, impact). All pole scores are recorded in TDPUD's GIS system. • Non-expulsion Current Limiting Fuses —An ongoing program to install non-expulsion or current limiting fuses in high fire risk areas. • FR3 Insulating Fluid — In 2008 TDPUD switch exclusively to FR3 dielectric fluid, and it is now a requirement for all new oil-insulated equipment. FR3 has an extremely high flash point that is more than two times that of its traditional mineral oil counterparts. • Covered Primary Jumper Wire—TDPUD is implementing the use of covered (i.e., tree wire) primary jumpers wire in place of bare wire. The covered primary jumper wire helps to minimize unintentional contact with wildlife and windblown debris, reducing wildfire risk. • Proposed Service Requirements — Since 1995 TDPUD has required all new or reconstructed developments take service via an underground system. TDPUD has also outlined considerations in Section V.0 Proposed Service Requirements that provide more detail to the requirement based upon project or instillation. • Tree Attachment (Legacy Attachments) —TDPUD does not allow new tree attachment in its system. When a legacy tree attachment fails or is damaged a new utility pole is installed and used for securing the secondary attachment. TDPUD's contract tree crew clear tree attachment areas and perform an inspection as part of the clearing process. They then notify TDPUD staff of any hazard for immediate mitigation. • Advance Metering Infrastructure (AMI) —TDPUD has invested in AMI across the entire service territory. AMI is an integrated system that enables two-way communication between utilities and customers. It also allows TDPUD to automatically send outage notifications to OMS, and to identify and isolate outages. • Outage Management System (OMS) —TDPUD has invested in a new OMS system in 2022. TDPUD's OMS automatically captures outage information in real time and allows TDPUD to respond to electrical outages and system hazards in a timely manner. • Supervisory Control and Data Acquisition —TDPUD has invested in a robust fiber-based SCADA system that allows staff to operate the substation reclosures remotely. TDPUD is investing an upgrade that would allow for SCADA control of all critical field reclosures. Overall TDPUD has a very detailed and robust preventative strategies, and programs in place for preventing wildfires that align with industry best practices. Page 9 Page 133 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan 3.4 Metrics' In section VIII.A, TDPUD describes how it tracks three metrics to measure the performance of its WMP. These metrics are: • Fire Ignitions • Wire-Down Events • Outage Causes For each of these metrics TDPUD provides detail to how it evaluates the metric and outlines the reporting requirements associated with each. TDPUD also provides for Fire Ignitions and Outage Causes the 2022 metric totals, noting zero fires ignitions caused by TDPUD occurred and 309 outages were recorded. 3.5 Disabling Recloserss TDPUD disables all automatic reclosing function for all automatic circuit reclosures (ACRs or reclosers) on its system during fire season. Fire season is typically defined as June 1 through October 31 but may be modified due to weather conditions and fire danger. With the reclosers disabled (one-shot operation), there will be no reclosings of circuits during fire season which greatly reduces the risk of vegetation ignition. TDPUD notes it will not allow reclosing of a line during fire season until the cause of the trip is identified and cleared, or the line has been fully visually inspected and found clear. 3.6 De-Energizing Protocols' Section V.H discusses TDPUD's evaluation of the efficacy of a PSPS type of de-energization program. This evaluation included coordination with sister POUs, TDPUD water utility staff and in communication with local public agencies and involved a list of major considerations that can be found in the section. Based on the evaluation, TDPUD determined that the risks of implementing a PSPS-type program outweigh the chances that TDPUD's electric overhead distribution system would cause a catastrophic wildfire. However, TDPUD discusses that, on a case-by-case basis, it will continue to consider de-energizing a portion of its system in response to a known public safety issue or in response to a request from an outside emergency agency. TDPUD also provides detail regarding its dependence on NV Energy as its transmission provider. NV Energy has its own pre-emptive de-energization program called Public Safety Outage Management (PSOM) and has included TDPUD's service territory in its program. NV Energy and TDPUD have held a series of meetings to fully understand the conditions in which NV Energy would de-energize transmission assets and develop communication protocol. These protocols outline NV Energy notification to TDPUD as well as TDPUDs notification to key agencies and customers. These meetings will continue in 2023. 6 PUC Section 8387(2)(D)and PUC Section 8387(2)(E) 6 PUC Section 8387(2)(F) PUC Section 8387(2)(F) Page 10 Page 134 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan 3.7 Event Communication' Section V.H Customer Notification Protocol describes TDPUD's development and maintenance of a list of critical agencies/emergency responders and its commitment to make direct communications, should NV Energy announce a potential PSOM event. Following receipt of notification of possible PSOM TDPUD staff will contact the list via phone, text, and/or email using all channels until contact and message receipt are confirmed. TDPUD also details how all customers are notified of wildfire alerts, related outages, potential PSOM outages, relay setting outages, and re-energization using the contact information in their customer accounts as well as through individual alerts via a TDPUD's customer engagement tool (MyAccount/SmartHub). Customer notification can occur via a variety of channels included text and email. TDPUD also makes available outage information via its website and real time outage maps, and in significant outage events social media. Nixle posts will occur in instances of major transmission and system wide outages. 3.8 Vegetation Management' Section V.D and Appendix D describing how TDPUD's vegetation management program meets (1) Public Resources Code section 4292; (2) Public Resources Code section 4293; (3) GO 95 Rule 35; and (4) the GO 95 Appendix E Guidelines to Rule 35. TDPUD's vegetation management program currently on a 5-year tree trimming cycle and is well designed to reduce wildfire hazards. TDPUD also details in Section V.D how all contractors and internal staff are equipped with mobile devices to record location and dates of vegetation management activities. These activities along with tree trimming are recorded in TDPUD's GIS and are used for reporting yearly progress and planning future routes and locations. TDPUD also records customer calls regarding concerns for potential tree hazards and can generate service orders for crews to respond, evaluate and record the outcome of the reported hazard. 3.9 Infrastructure Inspections10 Section V.E describes TDPUD's Inspection program, including that it meets the minimum inspections requirements and cycles included in CPUC GO 165, Table 1 and CPUC GO 95 Rule 18. TDPUD additionally inspects its HFTD facilities on a more frequent basis that its non- HTFD facilities. TDPUD's GIS contains records for inspections performed on the electrical system as part of its GO Inspection Program. The TDPUD staff performing the inspections are equipped with mobile devices that allow them to document the inspection as well as report any potential issues needing correction. TDPUD has also moved to using GIS to capture potential tree hazard associated with electrical lines and equipment. 8 PUC Section 8387(2)(G) 9 PUC Section 8387(2)(H) 10 PUC Section 8387(2)(1) Page 11 Page 135 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan TDPUD set's a goal annually to perform all inspections prior to June 1, the historical beginning of fire season for its service territory, but it will adjust the timeline if conditions, such as drought, require it. 3.10 Risk Assessment and Drivers" Section IV describes TDPUD's risks and drivers associated with Design, Construction Operation and Maintenance (IV.A), Topographical and Climatological Risk Factors (IV.B), and Enterprise- Wide Safety Risk (IV.C). These three categories are summarized in detail below. Design, Construction, Operation, and Maintenance TDPUD states that it designs and constructs its electrical facilities to meet or exceed the relevant federal, state, or industry standards. TDPUD also identifies the following risk drivers within its service territory: • Expulsion fuses still in use in portions of the TDPUD service territory • Utility poles reaching the end of the service life • Combustible poles in the High Fire Threat District (HFTD) • Limited staff and equipment • 134.7 miles of overhead distribution wires; 64% of overhead wires are in a HFTD • Overhead circuits in areas with poor road access Topographical and Climatological TDPUD's service territory is located between 6,000 and 8,000 feet of elevation on the eastern slope of the Sierra Nevada Mountain Chain near Lake Tahoe. TDPUD experiences the most severe weather during the winter months where severe storms can bring damaging levels of snow or rain and extreme winds sometimes exceeding 80 mph. During fire season, TDPUD experiences fast-moving, low-pressure systems that may bring high winds and dry lighting. TDPUD also provides climate change data that highlights changes over the last 80 years as well as the projected future weather changes by 2050 and 2080 based off current state analysis. TDPUD also identifies the following risk drivers: • Overhead circuits traverse mountainous areas of mixed conifer forests with continuous surface fuels, including annual grasses, herbaceous vegetation, and patches of woody shrubs. • Overhead circuits traverse areas of steep slopes. Several circuits are on slopes or in canyons aligned with the prevailing winds (Interstate 80 corridor). • Summertime precipitation in the area occurs in the form of afternoon thunderstorms; these storms may come dry lightning with very little precipitation. • Prevailing winds align with the Interstate 80 corridor resulting in strong winds through the center of the TDPUD service territory. Enterprise-Wide Safety Risk " PUC Section 8387(2)(J)(i); PUC Section 8387(2)(J)(ii); PUC Section 8387(2)(L) Page 12 Page 136 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan TDPUD states that it uses a methodical approach to address/mitigate enterprise-wide safety risk. According to TDPUD, "this approach uses both risk assessment and intimate knowledge of its operational practices" to analyze the safety risks. TDPUD evaluates the following as part of its risk assessment: • Pole Replacement Ranking Tool (Exhibit C) • Unavailability of NV Energy's transmission because of an outage or planned PSOM de- energization event due to existing wildfire • Interconnection and distribution interconnection • Unavailability of California Pacific Electric Company/Liberty Utilities' alternate distribution feed • Loss of internet connectivity • Loss of radio communications • Loss of cellular communications • Impacts of system de-energization • Impacted roadways limiting movement of personnel and equipment 3.11 Asset Overview and Service Territory12 Section I of the WMP describes in detail the make-up of TDPUD's service territory. TDPUD is a transmission-dependent utility connected to NV Energy's transmission system and is located high on the eastern slope of the Sierra Nevada. TDPUD is not directly interconnected with the California transmission system nor to any California utility in a meaningful way. TDPUD's electric service territory comprises approximately 44 square miles in eastern Nevada County and approximately 1.5 square miles in adjacent Placer County. The electric system includes approximately 225 miles total with 135 miles of 12.47 kilovolt (kV) and 14.4 kV overhead distribution lines, and about 0.5 miles of 60 kV overhead transmission lines. In total, TDPUD has 5,490 poles in its service territory. TDPUD also completed the following table which provides numerical details of its service territory and the assets within it. Table 3-1 —Truckee Donner Context Setting Table Utility Name Truckee D• DP Service Territory Size 45.5 square miles Owned Assets ❑X Transmission ❑X Distribution ❑ Generation Number of CustomersServed 14,648 customer accounts Population Within ServiceTerritory 17,131 people Customer Class Makeup Number of Accounts Share of Total Load(MWh) 12 PUC Section 8387(2)(K) Page 13 Page 137 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan 88.65% Residential 59.96% Residential 2.07% Government 16.64% Government 0%Agricultural 0%Agricultural 9.23% Small/Medium Business 20.11% Small/Medium Business .05% Commercial/Industrial 3.29% Commercial/Industrial .039%Agriculture Service Territory 2.641% Barren/Other 54.95/o Conifer Forest 0%Conifer Woodland 0% Desert .75% Hardwood Forest 0% Hardwood Woodland Location/Topography) 2 99% Herbaceous 26.92%Shrub 7.66% Urban 4.11%Water Service Territory 29.56%Wildland Urban Wildland Urban Interface" (based on Interface19.90%Wildland total area) Urban Intermix Percent of Service 0 Includes maps (Appendix A) Territory in CPUC High Tier 2: 55.07% FireThreat Districts (based on total area) Tier 3: 27.15% 0 Includes maps (Appendix B) Prevailing winds were taken from both the Global Winds Atlas and Wind Rosedata from archived records and assembled by Iowa State University. Prevailing Wind Gradientwinds are generally out of the south/southwest shifting to Directionsand Speeds west/southwest inthe spring and summer months.The average wind speed by Season is 4.4 mph with frequent gust in excess of 20 mph throughout the year. TDPUD's extreme weather and wind events occur in winter months when wildfire threat is typically low.These events are caused by atmospheric rivers and can bring winds in excess of 100 mph.These atmospheric river events and heavy snow falls are the reason TDPUD builds to a heavy 13 Based on the Wildland Urban Interface Maps available from the U.S. Geological Survey website titled "Wildland- urban interface maps for the conterminous U.S. based on 125 million building locations" (Carlson et al. 2022). Page 14 Page 138 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan loading standard and is able to withstand extreme weather events. Source: https://globalwindatlas.info; https://mesonet.agron.iastate.edu/sites/windrose.phtmI?network=CA_ASOS &station=TRK Overhead Dist.: 134.7 miles Overhead Trans.: 0.3 miles Underground Dist.: 97.6 Miles of Owned Lines miles Underground Trans.: 0 Underground and/or miles Overhead Explanatory Note 1-Methodology for Measuring "Miles": [e.g., circuit miles, line miles.] Data from GIS system Explanatory Note 2—Description of Unique Ownership Circumstances: N/A Explanatory Note 3—Additional Relevant Context: [e.g., percentage of lines located outside service territory] N/A Overhead Distribution Lines as%of Total Distribution System(inside and Percent of Owned Outside Service Territory) Lines inCPUC High Fire Tier 2: 23.02% Threat Districts Tier 3:40.59% Page 15 Page 139 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan i �YruCklt OO�H Piap6c Upia L\iVKI (T�Pilbi Senrirx Terttdy 'l . Tnxkee l7onw Pc"io Uhiy Serece Tyr titaa Figure 3-1 —Service Territory Map 3.12 Restoration14 Section VII Restoration of Service, details how TDPUD does not have a PSPS-type operational practice but it may de-energize a portion or all of its overhead circuit system for three specific situations. Those situations are: • If an outage emergency management/ emergency response agency requests a power shutdown. • If TDPUD elects to de-energize segments of its system due to extreme weather or other safety considerations. • As a result of a NV Energy PSOM event or transmission outage. TDPUD also noted that following an outage during wildfire season, staff will patrol the affected portion of the system before the system is re-energized, including following a trip of a recloser that is set to one-shot mode for the fire season. While TDPUD does not have a PSPS-type operational practice they do participate with California Emergency Management, and California Utilities Emergency Association. Additionally, with NV Energy being the primary provider of power to the TDPUD system, TDPUD staff have worked in close collaboration with NV Energy staff to develop a re-energization protocol as well as communication protocol and general best practice inspection and re- energizations practices. 14 PUC Section 8387(2)(M) Page 16 Page 140 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan Both TDPUD and NV Energy are committed to restoring power to its customers as quickly and safely as possible. 3.13 Monitoring and Auditing the Plan15 Section VIII.0 describes how the WMP is monitored and audited. Specifically, the WMP states that TDPUD evaluated the programs described in its WMP on an ongoing basis. The progress data and data regarding the metrics plus outage information are reviewed by the Electrical Utility Director. On a semi-annual basis the Electrical Utility Director will update the General Manager regarding the Plan's implementation, identified deficiencies, or recommendations for updating. Any critical or immediate concerns will be brought to TDPUD's Board of Directors. TDPUD also presents the WMP to its Board of Directors for review on an annual basis. 3.14 Annual Review16 Section VIII.D also describes TDPUD's process to annually review and update the WMP following the identification of deficiencies or recommendations. 15 PUC Section 8387(2)(N)(i)and PUC Section 8387(2)(N)(ii) 16 PUC Section 8387(2)(N)(iii) Page 17 Page 141 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan 4. Fire Industry Practices Comparison In consideration of industry-accepted and demonstrated mitigation measures, Guidehouse is providing a comparison against approved California utility WMPs, where comparable to TDPUD by service territory, risk profile, and equipment within the HFTD. This comparison is separate and additional to the regulatory evaluation required by PUC Section 8387(c). The complete comparison matrix with supporting information is provided in Table 4-1 — Industry Practice Strategy Comparison Matrix. Five areas have been highlighted for detailed discussion of the applicability and efficacy of the proposed WMP strategy. 4.1 Best Practice Comparison The following describes the scoring determinations of the benchmarking practice. Guidehouse weighed strategies that have been demonstrated globally as well as from those proposed by state utilities. As expressed in Figure 4-1, this benchmarking practice supports efforts to determine the Plan's comprehensiveness when investigating the mitigation measures proposed in TDPUD's WMP. This assessment is designed to confirm prudent measures as proposed by TDPUD and did not result in any material findings that would result in non-compliance or lack of comprehensive WMP elements. Meets the state and federal requirements and aligns with the identified benchmarking practices The Plan does not effectively describe the mitigation measure to warrant a sound determination or the strategy does not align with the presented best practice strategy. For the purpose of this evaluation, exploratory considerations of proposed best practice measures would fall under this category. 0 The strategy does not apply to the Utility or their risk exposure to wildfire events Figure 4-1 — Determinations for Benchmarking The selected strategies represented in Table 4-1 include both statutory requirements that exist as industry standards for POUs as well as accepted industry practices within the state. Page 18 Page 142 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan Table 4-1 — Industry Practice Strategy Comparison Matrix Situational Awareness/Weather Conditions Identified Practice Mitigation Rationale TDPUD Plan Elements Determination Strategy Applicability Real-time situational Having access to internal Especially in the TDPUD monitors current and awareness of and external mechanisms HFTD, weather forecasted weather data from a conditions that lead too track fire conditions stations and variety of sources including: US high risk of wildfires (high wind, dry conditions, cameras would National Weather Service, US TDPUD may also requires a multi- high heat), will aid in allow TDPUD Forest Service Wildland Fire ant to consider faceted approach responding to and personnel to have Assessment System, Northern following the National including but not preventing potential fires access to real-time California Geographic Area Fire Danger Rating limited to coordination by enacting related monitoring of these Coordination Center, and Local System (NFDRS) as with local public protocols during fire watch areas weather data from NV Energy an additional tool to agencies, weather conditions and Liberty Utilities monitor fuel monitoring, strategically placed conditions. high visibility cameras and other early warning systems. Cameras with night Visual inspections can be Remote cameras, TDPUD does not use or have DPUD's plan does vision mode capability enhanced using cameras especially those future plans for remote not include other atop of electrical with high definition and with infrared can cameras that may include means of tracking structures night vision capabilities. help TDPUD and infrared capabilities. such as leveraging This measure improves public safety the AlertCA (formerly response times in partners quickly IertWildfire) camera addressing risk incidents identify ignitions network, which and de-energization before they become already maintains unmanageable cameras in the Lake wildfires. Tahoe/Donner regions.. Page 19 Page 143 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan System Hardening/Design & Construction/Operational Practices Identified Practice Mitigation Rationale TDPUD Applicability Plan Elements Determination Strategy TDPUD has 134.7 miles of overhead distribution and 97.6 miles of Selective undergrounding is underground an effective option for distribution in its hardening electric facilities service territory. or wildfires. The selection 40.59% of the total criteria can include areas of distribution assets TDPUD has an high tree density, circuits are overhead lines Poles and overhead wires within established Selective that may be impacted by in Tier 3 with an known areas of high fire severity ° undergrounding undergrounding of de-energization, and areas additional 23.02/o in distribution facilities with limited ingress and zones or past wildfires, should be Tier 2. 42.01% of program and has within Tier 2,3. egress. Often, areas with considered for selective TDPUD's undergrounded a mountainous terrain are not undergrounding distribution system large portion of its distribution system good candidates for is underground. undergrounding of OH lines due rights of way and TDPUD also construction continues to complications recommend underground new or reconstruction developments in its service territory. Page 20 Page 144 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan TDPUD is implementing the use of covered (i.e., tree wire) primary jumper wire in place of bare wire. Primary Covered wire is a well- jumpers are used to demonstrated prevention connect TDPUD should method to sparks/ ignitions TDPUD has overhead distribution transformers, continue its Replacing bare during severe weather lines in Tier 2 and Tier 3. This area underground risers, program to install wires with covered conditions. Several utilities may benefit from additional and fuse cutouts to covered conductor conductors are employing pilot hardening such as covered wire main overhead in high-risk areas, programs of covered wire replacement for existing legacy bare circuit conductors. especially those replacement of distribution wire. The use of covered not fit for lines, prioritizing HFTDs for primary jumper undergrounding. implementation. wires helps to minimize unintentional contact with wildlife and windblown debris. New or planned TDPUD states it electrical lines meets or exceeds s new capital the heavy loading (distribution and infrastructure plans are Construction of distribution facilities standards of GO 95 transmission) that meet or exceed GO 95 standards. developed, it would be due to its elevation. are designed to Specifically, TDPUD increases pole TDPUD practices withstand working prudent to consider resilient strength requirements to meet the Accordingly, TDPUD align with industry GO 95 safety factors design standards that can has implemented loads under the withstand sustained winds y . construction best practices. stress above and gusts that occur during standards that are design standards to address high Red Flag Warning periods. designed to wind speeds withstand sustained heavy winds. Page 21 Page 145 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan When considering pole TDPUD's District's Steel or composite replacement strategies, construction when applicable composite poles swapped out or steel poles can reduce standards described s part of its pole or wood poles, at Poles within known areas of high fire in the WMP do not he risk that wood poles replacement minimum, within severity zones or past wildfires, include HFTDs or present. At minimum, fire should be considered for consideration of program, TDPUD retardant material can be should consider fireproofing replacement with more fire resilient steel pole or fire- ooden poles (fire coated to temporarily materials. retardant wood he use of steel or resistant material enhance the ability to poles for composite poles. coating) prevent fire spread or construction within impact the stability of the structure under fire threat. Tier 2,3. TDPUD's pole replacement program uses a mix of factors 1. age, 2. condition, and 3. critical asset GO 165 is considered a "best o evaluate when a practice" by many public owned TDPUD uses its pole should be Carry out programs that utilities. GO 165 Section III A (5) Pole Replacement replaced along with Pole loading address pole loading issues defines "Intrusive" inspection as one Ranking tool in its normal assessment, pole addition to inspections. intrusive inspection and inspections that would involving movement of soil, taking performing However, TDPUD result in remediation to samples for analysis, and/or using and testing infrastructure. more sophisticated diagnostic tools inspections in replaced only 14 beyond visual inspections or accordance with poles identified as instrument reading. GOs 95 and 165. high priority replacements in 2022 (92 total poles were replaced including inter storm damage and other work) and the RankingTool Page 22 Page 146 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan procedure suggests TDPUD should replace 100-180 poles per year to stay current. TDPUD evaluated the uses of non- Traditional fuses pose a fire expulsive fuses from risk due to the ignited 2019-202. Following material that can be HFTDs would benefit from the that period, TDPUD expelled. Best practices for embarked on a replacement of traditional fuses with mitigating this risk is to ones that minimize sparks and arcs program to replace TDPUD's plan to change out these fuses with all of its overhead replace all Expulsion fuse non-expulsive fuses. Electrical systems use fuses and fuses in three years. overhead fuses device change out circuit breakers to protect electrical and track their to current-limiting A protective device TDPUD selected (non-expulsive) coordination study achieves equipment. Equipment failures and Eaton's Cooper actions through its uses an optimum balance other anomalies may cause a short Power Systems full- OMS aligns with circuit. Risks are reduced within industry best between equipment range, current- protection and selective HFTDs when a short circuit impacts limiting, dropout practices. isolation that is consistent only that portion of the system Energy Limiting with the operating where the failure occurs. Fuse (ELF) for the requirements of power pilot project. The systems. ELF fuse has been granted permanent exemption by CAL FIRE from ole Page 23 Page 147 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan clearance requirements. However, due to a recall in 2021, and supply chain issues, this program has been delayed and likely will not be complete in 2024. TDPUD expects to resume this effort in 2023. TDPUD has legacy tree attachment hazard mitigation strategy. All tree This practice involves the attachments are removal of electrical tracked on GIS, all DPUD's practice infrastructure fastened to attachments are of mitigating risks Tree attachment trees for infrastructural TDPUD has numerous legacy tree inspected, trimming rom tree removals support but can be a source attachments in its territory. is performed around attachments aligns of ignition. The removal of the attachment, and with industry best these legacy devices may when an existing practice. reduce electrical spark risk. attachment fails or is damaged, a new pole is installed and used for securing all secondary attachments. Page 24 Page 148 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan TDPUD disables reclosers during the Disabling reclosers fire season (typically through blocking June 1 through reclosing October 31 but may operations Reclosing operations should be be extended or (distribution level) defined within the Plan as per shortened due toconditions). During DPUD's recloser in HFTDs during Disabling reclosing reduces statute PUC 8387 (b)(2)(F) this time, all practices during the fire season he number of potential reclosers are set to ire season align and/or during Red ignition events during a fault Operational best practices align with one-shot operation. ith utility best Flag Warnings condition having settings that align with fire one-shot that trip practice. issued by the potential weather conditions to Reclosers during this period National Weather prevent potential ignition will not be closed Service (or as fire risk potential until the cause of the designates) trip is identified or the line is visually inspected and found clear. Routine ground patrols are implicit practices in equipment and vegetation Ground patrols are a required inspection protocols. DPUD's actions strategy in ensuring safe and Increasing the frequency, are consistent with Ground patrol as reliable delivery of electricity. When TDPUD conducts especially in the HFTD, utility best well as aerial access concerns arise, aerial ground patrols as represents an effective practices for inspection inspections provide better coverage part of its inspection practices preventative measure and in surveying and inspecting electrical program. ground patrols and ensures the integrity of inspection electrical equipment. Aerial equipment throughout the utility practices inspections, by way of service territory helicopters, will lead to greater coverage of the service territory and areas Page 25 Page 149 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan adjacent to required clearances While TDPUD does not maintain "Wildfire Infrastructure n internal team to help Protection Teams," coordinate efforts to ensure TDPUD trains all its DPUD's actions he Plan is being followed An internal team to prepare and staff annually on the o respond to as well as coordinating protect physical aspects of the following: the ignitions are Wildfire content of the WMP, Infrastructure efforts to enhance the electric system as well as ensure consistent with Plan's strategies and quality effective mitigation measures are proper use and industry best Protection Teams check that activities are carried out would be a prudent storage of fire practices for a being performed and activity to pursue extinguishers, utility the size of racked aligning with the required pre-job TDPUD. Plan briefings to discuss ignition potential and environmental conditions, and to identify the closest fire extinguisher. Establishment of TDPUD's WMP Section V.B Operational procedures and routine imposes additional Weather activities limitations operational practices that responsibilities and Monitoring during the fire limit or curtain operational Limiting operational practices may limits certain describes the fire season and/or activities during periods of reduce the probability of inadvertent activities during weather conditions during Red Flag increased risk within fire ignitions by utility workers and utility extreme fire-risk from normal to Warnings issued threat districts. These contractors conditions or during RFW days and the by the National procedures and practices Weather Service provide employee and Red Flag Warning operational (RFW) events (or as fire risk contractors specific . measures TDPUD information and instructions takes to ensure Page 26 Page 150 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan potential to improve the reliable and safety during such designates) safe operations of electric conditions. facilities and mitigate the threat of utility caused inadvertent ignitions. Vegetation Management Identified Practice Mitigation Rationale TDPUD Plan Elements Determination Strategy Applicability Routine vegetation State and federal PRC sections 4292 TDPUD's WMP and Vegetation management & compliance for vegetation and 4293; GO 95 is Management Program state inspections in management and required by the that they meet or exceed TDPUD's actions are accordance with: inspection, as well as CPUC for investor- minimum industry standards consistent with utility Public Resources California Public Utilities owned utilities. for PRC 4292, PRC 4293, GO best practices for Code (PRC) 4292 & Commission GO 95, which 95 Rule 35 and Guidelines to routine vegetation 393, General Order is accepted as industry Public Owned Rule 35. TDPUD maintains a management (GO) 95 Rule 35 and standard amongst all Utilities (POUs) five-year to a vegetation inspections. Appendix E, and utilities. (Community and generally follow management cycle but will ANSI A300 investor owned). these guidelines. remove any vegetation hazard spotted by its crews, Page 27 Page 151 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan contractors, or customers as quickly as possible. TDPUD maintains a standalone comprehensive vegetation management plan (last revised May 2022) that complies with these statutes. Guidehouse reviewed the Vegetation Management Plan. II vegetation management activities are recorded on mobile devices and tracked in GIS. TDPUD tracks all vegetation activities including trees trimmed or removed. Within the HFTD, TDPUD identifies and tracks danger trees could hazard trees through its pose a greater inspection program and their Recording and tagging potential to catch on removals are tracked in GIS. Hazardous Customer calls regarding trees that pose risks to ire or contribute to TDPUD's actions are adjacent electrical ire spread. consistent with utility identification and tree/vegetation equipment or are Addressing Hazard trees are removed as though hazard trees are tracked. best practices for removal protocols dead/dying are considered identification and hazard tree and programs prudent efforts for surveying, as well quickly as possible. identification and vegetation management as implementi Additionally, TDPUD will seek ng to remove any dead tree within removal. practices remediation 200 feet of any HV line will be activities will result removed, regardless of in further wildfire ownership. risk reduction Page 28 Page 152 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan Within TDPUD's HFTD, impact trees could pose a TDPUD identifies and tracks greater potential to hazard trees through its catch on fire or inspection program and hazard Off-Cycle / Call-in contribute to fire TDPUD's off-cycle / trees and their removals are vegetation removal or Off-cycle practices of spread. Addressing call-in vegetation 'tracked in GIS. Customer calls corrective work, vegetation inspection and though identification removal or corrective regarding hazard trees are especially during the management and surveying, as work aligns with ire season well as tracked and service orders are industry practice implementing created for crews to respond mple n to. Hazard trees are removed remeactivities will result as quickly as possible. in further wildfire risk reduction Emergency Response & Recovery Identified Practice Mitigation Rationale TDPUD Plan Elements Determination Strategy Applicability Page 29 Page 153 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan Notify critical facilities and public safety partners, which may Following a sequence of TDPUD maintains customer include first events in contacting public notification protocols to alert responders, incident safety partners and customers in case of origin law impacted community emergencies, which includes enforcement, acute facilities will enable Notification the possibility of NV Energy health care facilities, quicker response in practices targeting cutting transmission deliveries TDPUD emergency essential service reacting to an emergency key stakeholders through a Public Safety Outage notification protocols providers, related event (such as a wildfire orare crucial during Management (PSOM) align with utility best governing local and de-energization). Utilities emergency events activation. This is detailed in practices. state agencies, should describe their such as storms and Section V.H of the WMP. adjacent jurisdictions, processes to notify critical wildfires. TDPUD also conducts vulnerable facilities as it applies to significant stakeholder populations, and the their service territory and outreach which is described in Independent System impacted communities as Operator (ISO) (for well as grid operators. Section VI of the WMP. transmission level de- energization) Establishment of TDPUD leverages the Using the State Emergency Action California Governor's Office of Emergency Management Plans between the Emergency Services' Incident Command System (SEMS) Electric Standardized Emergency Team / Emergency framework, which is Department, the Management System (SEMS) determined on the Federal City Emergency framework in designing Operations Emergency Management Operations Center emergency response protocols. T follows an frameworks in the gency (FEMA) structure and other City designated team or group of emergency ergency operations event a de- :�. framework that utilizes energization event or or incident command departments individuals have the ability to utility best practices. wildfire incident protocols will ensure assures effective relay information to important prepared and adequately identification, stakeholders, partners, and occurs trained staff to respond in assignment and customers and make informed effective communication training for decisions during emergency manners as well as emergency response events. During such respond to risk events in a management roles. events, the Town of Truckee, Nevada County, and Placer Page 30 Page 154 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan sequence of effective County will lead emergency procedures. operations and disaster responses, TDPUD will contribute to these efforts and establish its own Emergency Operations Center. Page 31 Page 155 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan 5. Results and Discussion Guidehouse finalized this assessment on May 25, 2023. Over the course of reviewing TDPUD's WMP, discussions with TDPUD staff, and review of supporting documentation, Guidehouse captured takeaways and findings that align the WMP with state laws and effective wildfire measure demonstration for a utility of TDPUD's size and risk profile. TDPUD's WMP appropriately responds to each of the required elements of PUC Section 8387, which is detailed in Appendix A. The following describes the assessment and resulting findings of the WMP's proposed and established mitigation measures as it applies to safe, reliable operation of all electric infrastructure and wildfire prevention and response. Report Conclusions After internal review of the latest version of the WMP and associated data collection products, Guidehouse concludes this Report with the following: • TDPUD's WMP aligns appropriately with PUC Section 8387 and includes all required elements." • TDPUD's WMP is comprehensive as described through this Report in accordance with PUC Section 8387. " Following acceptance of this Report, TDPUD will post the Report and results online for public view.The Report is scheduled for presentation to the City Council at a public meeting in June 2023.Accomplishing these follow-up tasks will meet all required statutory provisions up until presenting the final WMP to the City Council. Page 32 Page 156 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan Appendix A. Statutory Compliance Matrix Meets Plan TDPUD Plan Elements Section Required Statutory Element Section (Summarized) Elements (Determination (a) Each local publicly owned electric utility and electrical cooperative shall construct, maintain, and operate its electrical lines and equipment in a manner that will minimize the risk of wildfire posed by those electrical lines and equipment. (b) (1)The local publicly owned electric utility or electrical cooperative shall, before January 1, 2020, prepare a wildfire mitigation plan.After January 1, 2020, a local publicly owned electric utility or electrical cooperative shall prepare a wildfire mitigation plan annually and shall submit the plan to the California Wildfire Safety Advisory Board on or before July 1 of that calendar year. Each local publicly owned electric utility and electrical cooperative shall update its plan annually and submit the update to the California Wildfire Safety Advisory Board by July 1 of each year.At least once every three years, the submission shall be a comprehensive revision of the Ian. (2)The wildfire mitigation plan shall consider as necessary, at minimum, all of the following: TDPUD has a Roles and Responsibilities section in its plan with An accounting of the descriptions of the roles of the responsibilities of persons General Manager(Chief Executive), responsible for executing the Section III.A Public Information Officer, Electric Yes plan. Utility Director/Assistant General Manager, Electrical Operations Manager, and the Electrical Engineering Manager. Confidential information for the sole benefit and use of Truckee Donner Public Utility District. Page A-1 Page 157 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan TDPUD has clearly stated objectives The objectives of the wildfire in its plan. 1) Minimize Sources of mitigation plan. Section II Ignitions; 2) Resiliency of the Electric Yes Grid; 3)Minimizing Unnecessary or Ineffective Action. A description of the preventive strategies and Section 5 provides a detailed programs to be adopted by the description of TDPUD's preventative local publicly owned electric utility strategies with specific subsections on or electrical cooperative to minimize the risk of its electrical Section V weather monitoring, design and Yes construction, vegetation management, lines and equipment causing inspections,workforce training, catastrophic wildfires, including consideration of dynamic climate recloser policies,and de-energization. change risks. A description of the metrics TDPUD tracks three metrics that the local publicly owned electric serve as leading indicators of wildfire utility or electrical cooperative and associated risks. These metrics plans to use to evaluate the wildfire mitigation plan's Section VIII.A are used by TDPUD to provide insight Yes performance and the into TDPUD's performance and assumptions that underlie the use dynamic conditions across TDPUD's of those metrics. service area. A discussion of how the TDPUD discusses in detail how the application of previously identified application of previously identified metrics to previous wildfire mitigation metrics to previous wildfire Section VIII.B plan performances has informed the Yes mitigation plan performances has & VIII.D wildfire mitigation plan.As well as informed the wildfire mitigation monitoring and correcting deficiencies plan. that may be identified. TDPUD discusses how its disables automatic reclosing function during fire season. Protocols for disabling TDPUD discusses de-energization in reclosers and deenergizing section 5.8.TDPUD has evaluated in portions of the electrical coordination with neighboring POUs, distribution system that consider TDPUD water staff, and in the associated impacts on public communication with local agencies, safety, as well as protocols Section V.G & the efficacy of a PSPS program. Yes related to mitigating the public V.H TDPUD does not have a PSPS plan safety impacts of those protocols, but will continue to consider de- including impacts on critical first energization in response to know responders and on health and public safety issue. TDPUD attends communication infrastructure. NV Energy meetings to understand instances when NVE would implement PSOM and how they will go about contacting TDPUD, and TDPUD will proceed with notifying their appropriate agencies. Confidential information for the sole benefit and use of Truckee Donner Public Utility District. Page A-2 Page 158 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan Appropriate and feasible procedures for notifying a customer who may be impacted by the deenergizing of electrical Section V.H TDPUD has developed a list of critical lines.The procedures shall Customer agencies/emergency responders Yes consider the need to notify, as a Notification should NV Energy announce a priority, critical first responders, Protocols PSOM. health care facilities, and operators of telecommunications infrastructure. TDPUD details its vegetation management program in its WMP. This program includes right of way Plans for vegetation clearing to 20 feet on all sides of utility management. Section V.D poles, removal of any dead trees Yes within 200 feet of HV lines, and hazard tree removal.TDPUD records all trimming activity in its GIS and trims all vegetation on a 5-year cycle Plans for inspections of the TDPUD's WMP states that it meets or local publicly owned electric Section V.E exceeds the inspection cycles and Yes utility's or electrical cooperative's requirements provided in GO 95 and electrical infrastructure. 165. A list that identifies, describes, and prioritizes all wildfire risks, TDPUD's WMP includes a and drivers for those risks, assessment of risk and risk drivers throughout the local publicly and addresses the topics of design, owned electric utility's or electrical Section IV operation, and construction,as well as Yes cooperative's service territory. topographic and climatological risk The list shall include, but not be factors. limited to, both of the following: Risks and risk drivers associated with design, construction, operation, and TDPUD identifies seven risk drivers maintenance of the local publicly Section IV.A associated with Design, Construction, Yes owned electric utility's or electrical Operation, and Maintenance. cooperative's equipment and facilities. Particular risks and risk TDPUD discusses the risks and risk drivers associated with drivers associated with its topographic and climatological climate/weather, topography, and risk factors throughout the Section IV.B Yes different parts of the local publicly vegetation and applies those to a owned electric utility's or electrical detailed analysis of its service territory. cooperative's service territory. Confidential information for the sole benefit and use of Truckee Donner Public Utility District. Page A-3 Page 159 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan Identification of any geographic area in the local publicly owned electric utility's or electrical cooperative's service TDPUD does not recommend territory that is a higher wildfire changes to the CPUC state-wide Fire threat than is identified in a Section IV.D & Threat Map. TDPUD,for the purpose Yes commission fire threat map, and V.A of its WMP,treats its entire service identification of where the territory as HFTD Tier 3(Extreme Fire commission should expand a Risk). high fire-threat district based on new information or changes to the environment. A methodology for identifying TDPUD uses a methodical approach and presenting enterprise wide to address/mitigate enterprise safety safety risk and wildfire-related Section IV.0 risk that utilizes both risk assessment Yes risk. and intimate knowledge of its operational practices. TDPUD's WMP provides a statement A statement of how the local of how it plans to restore service after publicly owned electric utility or Section VII a de-energization, including a Yes electrical cooperative will restore discussion of efforts to inspect the service after a wildfire. condition of the system prior to energization during wildfire season. A description of the processes and procedures the local publicly owned electric utility or electrical cooperative shall use to do all of the following: TDPUD states it evaluates its WMP on an ongoing basis. The Electrical Monitor and audit the Utility Director will semi-annually Section VIII.0 update the General Manager implementation of the wildfire Yes mitigation plan. VIII.F regarding implementation efforts. Board of Director review of the WMP occurs annual in a public setting with agenda material. Identify any deficiencies in the TDPUD has stated the Electric Utility wildfire mitigation plan or its implementation, and correct Section VIII.D Director is responsible for Yes those deficiencies. spearheading deficiency efforts. Monitor and audit the effectiveness of electrical line and TDPUD states it conduct ongoing equipment inspections, including tracking and annual review of inspections performed by Section VIII.E inspection findings. Electrical Yes contractors, that are carried out Operations Manager is responsible for under the plan, other applicable the VMP. statutes, or commission rules. Confidential information for the sole benefit and use of Truckee Donner Public Utility District. Page A-4 Page 160 of 315 / Guidehouse Independent Evaluation of Truckee Donner Public Utility District's 2023 Outwit Complexity Wildfire Mitigation Plan (3)The local publicly owned electric utility or electrical cooperative shall, on or before January 1, 2020, and not less than annually thereafter, present its wildfire mitigation plan in an TDPUD will presents its WMP to the appropriately noticed public Board at an annual meeting that are meeting.The local publicly owned open to the public. The TDPUD WMP electric utility or electrical Section 1.11) & is either adopted by vote following a Yes cooperative shall accept IX period for public comment or is comments on its wildfire returned to TDPUD for revision. The mitigation plan from the public, final adoption of the 2023 WMP by the other local and state agencies, Board is anticipated on June 7, 2023. and interested parties, and shall verify that the wildfire mitigation plan complies with all applicable rules, regulations, and standards, as appropriate. (c)The local publicly owned electric utility or electrical cooperative shall contract with a qualified independent evaluator with experience in assessing the safe operation of electrical infrastructure to review and assess the comprehensiveness TDPUD contracted with Guidehouse of its wildfire mitigation plan. The Consulting, Inc.to perform an independent evaluator shall issue Section VIII.F independent evaluation of its WMP. Yes a report that shall be made Qualifications are described in Section available on the internet website 1. of the local publicly owned electric utility or electrical cooperative,and shall present the report at a public meeting of the local publicly owned electric utility's or electrical cooperative's governing board. Confidential information for the sole benefit and use of Truckee Donner Public Utility District. Page A-5 Page 161 of 315